Recurring concern

Unreliable governance and public understanding of Physician Associate practice

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First reported 31 Jul 2024•Latest report 24 Feb 2025

Definition

What this concern includes

Includes failures in the dedicated Physician Associate practice framework, including public-facing role and status information, regulatory oversight, national training, supervision and competence requirements, registration or reporting arrangements, and controls needed to ensure Physician Associates work within clearly understood and accountable boundaries.

Not included

Excludes generic healthcare-professional regulation, credentialing, supervision or training deficiencies unless they specifically concern Physician Associate practice.
Excludes failures in the clinical care of an individual patient where no deficiency in the Physician Associate practice framework is identified.
Excludes neutral descriptions of the Physician Associate role, workforce or service use without an identified governance, role-understanding or safety-control deficiency.
Excludes generic public misunderstanding of healthcare professions where Physician Associates are not the material subject.

Reports: 2
Individual concerns: 10
Date range: 2024–2025
Stated actions: 41

Reports over time

Reports about this concern issued each year.

* 2026 is projected from reports observed to 7 Sep 2026.

Most frequent recipients

Reports about this concern sent to each recipient.

Department of Health and Social Care2

General Medical Council2

Association Of Anaesthetists (Great Britain & Ireland)1

Care Quality Commission1

Difficult Airway Society1

Faculty of Physician Associates1

NHS England1

Royal College of Anaesthetists1

Royal College of Emergency Medicine1

Royal College of Physicians1

Surrey and Sussex Healthcare NHS Trust1

Concerns and responses across reports

Only concerns grouped under this recurring concern are included. Select any concern, action or position to view the source wording.

24 Feb2025
Surrey
Concerns raised5
1. Failure to clearly explain and differentiate the Physician Associate role from medically qualified practitioners
2. Failure to inform patients and families that Physician Associates are not medically qualified
3. Lack of public understanding of the Physician Associate role
1. Failure to prevent Physician Associates undertaking roles outside their competency
2. Lack of regulated scope-of-practice guidance and recognised training for Physician Associates
This report raised 5 other concerns. They are not shown here because they do not form part of this recurring concern.
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
Actions described in response 18
1. Action
  Publish a summary of existing guidance on deploying medical associate professionals.
  Stated by NHS EnglandStated completed
2. Action
  Issue a position statement setting standards for Physician Associate supervision, identification, patient selection and regulation.
  Stated by Royal College of Emergency MedicineStated completed
3. Action
  Publish interim guidance requiring physician associates to explain their roles, supervision and educational or clinical background to patients, families, carers and colleagues.
  Stated by Royal College of PhysiciansStated completed
1. Action
  Identify Physician Associates through distinctive clothing, lanyards, and explicit introductions that clarify they are not doctors.
  Stated by Surrey and Sussex Healthcare NHS TrustStated completed
2. Action
  Install Emergency Department signage identifying clinical team members by their scrub colours.
  Stated by Surrey and Sussex Healthcare NHS TrustStated completed
3. Action
  Clearly distinguish doctors, physician associates and anaesthesia associates on public registers and in register searches.
  Stated by General Medical CouncilStated completed
4. Action
  Clearly communicate that physician associates are not doctors and must not replace doctors.
  Stated by Royal College of PhysiciansStated completed
5. Action
  Assess providers’ arrangements for safe recruitment, adequate staffing, supervision, accountability, governance, information-sharing and inclusive care involving Physician Associates.
  Stated by Care Quality CommissionStated planned
6. Action
  Engage medical Royal Colleges to facilitate broad aligning principles for physician associate and anaesthesia associate specialty scopes of practice.
  Stated by NHS EnglandStated completed
7. Action
  Contribute to the ongoing review of the safety and scope of the Physician Associate role.
  Stated by Royal College of Emergency MedicineStated in progress
8. Action
  Issue updated clinical-governance guidance supporting supervision, board-level responsibility and local governance of physician associates and anaesthesia associates.
  Stated by General Medical CouncilStated completed
9. Action
  Provide feedback on specialist professional bodies’ draft guidance concerning physician associate scope of practice.
  Stated by General Medical CouncilStated completed
10. Action
  Campaign with fellows and members to limit the pace and scale of physician-associate rollout until safe deployment systems are established.
  Stated by Royal College of PhysiciansStated in progress
11. Action
  Commission an independent review of Physician Associate and Anaesthesia Associate roles and their contribution to multidisciplinary healthcare teams.
  Stated by Department of Health and Social CareStated completed
12. Action
  Move Physician Associates to Tier 1 of the Emergency Department rota in line with updated national guidance.
  Stated by Surrey and Sussex Healthcare NHS TrustStated completed
13. Action
  Issue and implement an Emergency Department Physician Associate scope of practice requiring senior doctor oversight, appropriate patient selection, escalation, and medical review before discharge or admission.
  Stated by Surrey and Sussex Healthcare NHS TrustStated completed
14. Action
  Publish interim guidance for physician associates working in medical specialties.
  Stated by Royal College of PhysiciansStated completed
15. Action
  Amend the local Physician Associate governance policy to reflect changes in national guidance and regulation.
  Stated by Surrey and Sussex Healthcare NHS TrustStated completed
Respondent positions 15
1. Position
  Public terminology, role understanding and second-opinion rights fall outside the regulatory scope.
  Stated by Care Quality CommissionOutside remit
1. Position
  The General Medical Council is best placed to address public terminology, role understanding and second-opinion rights.
  Stated by Care Quality CommissionRedirects responsibility
2. Position
  Existing NICE and GMC standards require healthcare professionals to identify their role to patients, addressing role-identification concerns.
  Stated by Department of Health and Social CareExisting arrangements considered sufficient
3. Position
  “Physician Associate” is a nationally sanctioned term describing healthcare professionals with recognised training, rather than an inherently misleading title.
  Stated by Surrey and Sussex Healthcare NHS TrustDisputes the concern
4. Position
  The Trust considers that it has explained everything within its remit regarding patients’ and families’ ability to seek a second medical opinion.
  Stated by Surrey and Sussex Healthcare NHS TrustOutside remit
5. Position
  The General Medical Council is responsible for regulating individual Physician Associates, rather than this regulator.
  Stated by Care Quality CommissionRedirects responsibility
6. Position
  Existing CQC guidance and provider governance, supervision and competence requirements apply to Physician Associates in secondary care.
  Stated by Care Quality CommissionExisting arrangements considered sufficient
7. Position
  The College has no statutory or regulatory role in regulating physician associates.
  Stated by Royal College of Emergency MedicineOutside remit
8. Position
  Employers, clinical leaders and supervisors must determine PAs’ permitted activities and required supervision through local clinical governance.
  Stated by General Medical CouncilRedirects responsibility
9. Position
  Individual competence and clinical context vary, so GMC standards do not impose fixed ceilings on what registered PAs may do.
  Stated by General Medical CouncilDisputes the concern
10. Position
  The GMC is responsible for regulating physician associates, while national system leaders should develop their scope of practice and supervision framework.
  Stated by Royal College of PhysiciansRedirects responsibility
11. Position
  GMC regulation and existing NHS guidance already govern PA regulation, competence, scope, supervision and employer clinical governance.
  Stated by Department of Health and Social CareExisting arrangements considered sufficient
12. Position
  Existing national guidance, local governance policy and competency frameworks are considered sufficient to keep Physician Associates within their scope of practice.
  Stated by Surrey and Sussex Healthcare NHS TrustExisting arrangements considered sufficient
13. Position
  Monitoring or accrediting physician associate training is outside the College’s responsibility.
  Stated by Royal College of Emergency MedicineOutside remit
14. Position
  Royal colleges and specialist professional bodies should provide detailed specialty-specific guidance on physician associate scope of practice.
  Stated by General Medical CouncilRedirects responsibility
AI-generated summary

Pamela Anne Marking · Prevention of Future Deaths report

This summary was generated using AI from the published report. Please read the original report for the complete account.

Report summary

Pamela Anne Marking was admitted with abdominal symptoms, was diagnosed with a nosebleed by a Physician Associate and discharged without medical review or direct medical supervision. She later returned with small bowel obstruction caused by an incarcerated femoral hernia and aspirated feculent fluid during induction of anaesthesia for emergency surgery, subsequently dying from respiratory failure and sepsis. The concerns included the Physician Associate’s role, supervision and scope of practice, and the absence of updated guidance for rapid sequence induction, TIVA and airway protection.

Read the report on judiciary.uk
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Failure to clearly explain and differentiate the Physician Associate role from medically qualified practitioners
Wider context from the report
“1. The term ‘Physician Associate’ is misleading to the public Mrs Marking’s son was under the mistaken belief that the Physician Associate was a doctor by this title in circumstances where no steps were taken by the Emergency Department or the Physician Associate to explain or clearly differentiate their role from that of medically qualified practitioners. ”
Source location
Pamela Anne Marking · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Failure to inform patients and families that Physician Associates are not medically qualified
Wider context from the report
“3. The right of patients and family to seek a second opinion The lack of public knowledge that a Physician Associate is not medically qualified has the potential to hinder requests by patients and their relatives who would wish to seek an opinion from a medical practitioner. It also raises issues of informed consent and protection of patient rights if the public are not aware or have not been properly informed that they are being treated by a Physician Associate rather than a medically qualified doctor. ”
Source location
Pamela Anne Marking · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Lack of public understanding of the Physician Associate role
Wider context from the report
“2. Lack of public understanding of the role of Physician Associate Witnesses from the Trust gave evidence that a Physician Associate was clinically equivalent to a Tier 2 resident doctor without evidence to support this belief. This blurring of roles without public knowledge and understanding of the role of a Physician Associate has the potential to devalue and undermine public confidence in the medical profession whilst allowing Physician Associates to potentially undertake roles outside of their competency thereby compromising patient safety. ”
Source location
Pamela Anne Marking · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Failure to prevent Physician Associates undertaking roles outside their competency
Wider context from the report
“2. Lack of public understanding of the role of Physician Associate Witnesses from the Trust gave evidence that a Physician Associate was clinically equivalent to a Tier 2 resident doctor without evidence to support this belief. This blurring of roles without public knowledge and understanding of the role of a Physician Associate has the potential to devalue and undermine public confidence in the medical profession whilst allowing Physician Associates to potentially undertake roles outside of their competency thereby compromising patient safety. ”
Source location
Pamela Anne Marking · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Lack of regulated scope-of-practice guidance and recognised training for Physician Associates
Wider context from the report
“4. Lack of national and local guidelines and regulation of the scope of practice for a Physician Associate A diagnosis of epistaxis was made by the Physician Associate without appreciating the relevance of the vomiting and lower abdominal discomfort and in the absence of understanding the need to undertake palpation of the groins in an abdominal examination in a patient who was unable to give a proper clinical history because of short term memory loss. No evidence was presented that the management of Mrs Marking was subject to a reflective practice review. Given their limited training and in the absence of any national or local recognised hospital training for Physician Associates once appointed, this gives rise to a concern they are working outside of their capabilities. ”
Source location
Pamela Anne Marking · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Publish a summary of existing guidance on deploying medical associate professionals.

Verbatim wording from the response
“NHS England has published a summary of existing guidance on the deployment of medical associate professions for NHS organisations. This guidance makes it clear that all staff should introduce themselves and their role clearly and be supported by their employer to do so. This is in accordance with National Institute for Health and”

Source location
Response from NHSE
Page 1 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Issue a position statement setting standards for Physician Associate supervision, identification, patient selection and regulation.

Verbatim wording from the response
“Following a period of consultation and engagement with various stakeholders, in June 2024 the Royal College of Emergency Medicine (RCEM) issued a position statement regarding Physician Associates [1] which included the following:”

Source location
Response from RCEM
Page 1 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Publish interim guidance requiring physician associates to explain their roles, supervision and educational or clinical background to patients, families, carers and colleagues.

Verbatim wording from the response
“The RCP published interim guidance on titles and introductions for PAs in December 2024, in which we were clear that ‘PAs must clearly explain their role to patients, their families and carers, as well as colleagues and supervisors, and provide details of their educational and clinical supervision when required.’”

Source location
Response from Royal College of Physicians
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Identify Physician Associates through distinctive clothing, lanyards, and explicit introductions that clarify they are not doctors.

Verbatim wording from the response
“The term ‘Physician Associate’ is a national term, sanctioned by national bodies, and describes a particular group of healthcare professionals who have completed a recognised training programme. However, the Trust recognises that there is a lack of awareness amongst the public and indeed amongst some healthcare staff that Physician Associates are not medically qualified practitioners. Since we first employed Physician Associates (PAs) at the Trust we have tried to make this distinction as clear as possible. At the Trust, PAs always wear uniquely coloured”

Source location
Response from Surrey and Sussex NHS
Page 1 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Install Emergency Department signage identifying clinical team members by their scrub colours.

Verbatim wording from the response
“Within the Emergency Department, since the Inquest, we have installed clear signage throughout, identifying the different members of the clinical team by the different colours of scrubs that they wear.”

Source location
Response from Surrey and Sussex NHS
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Clearly distinguish doctors, physician associates and anaesthesia associates on public registers and in register searches.

Verbatim wording from the response
“Now that regulation is in effect, the registers on our website are clearly marked to distinguish between the three professions we regulate. A prefix is used for PA and AA reference numbers, which provides a clear distinction between those two professions and doctors. In addition, each profession type is prominently labelled on our public-facing registers, and in search functions. This means that when patients search our registers it will be very clear whether an individual is a doctor, a PA or an AA.”

Source location
Response from General Medical Council
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Clearly communicate that physician associates are not doctors and must not replace doctors.

Verbatim wording from the response
“Working with our fellows and members, the RCP will continue to actively campaign to limit the pace and scale of roll-out of PAs in the NHS until we are reassured that there are safe systems in place for PA deployment. We have repeatedly made clear that PAs are not doctors, and they cannot and must not replace doctors. We have also called on the UK government and the NHS to develop and publish an evidence-base and evaluation framework around the introduction of PAs. This should be a priority, and we are working with the RCP Patient Safety Committee to consider what more we can do to support this agenda.”

Source location
Response from Royal College of Physicians
Page 3 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Assess providers’ arrangements for safe recruitment, adequate staffing, supervision, accountability, governance, information-sharing and inclusive care involving Physician Associates.

Verbatim wording from the response
“We use these regulations when we assess if a provider is safe, effective, caring, responsive and well-led. The role of Physician Associates relates to:”

Source location
Response from CQC
Page 3 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Engage medical Royal Colleges to facilitate broad aligning principles for physician associate and anaesthesia associate specialty scopes of practice.

Verbatim wording from the response
“The GMC has published the generic and shared learning outcomes that PAs and AAs must be registered by them as the professional regulator. Taken with the PA curriculum, these documents will describe what all newly qualified physician associates must know and be able to do.”

Source location
Response from NHSE
Page 3 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Contribute to the ongoing review of the safety and scope of the Physician Associate role.

Verbatim wording from the response
“The role and regulation of PAs has been subject to much comment in recent years [3], we note that there is an ongoing review into the safety and scope of the PA role [4] to which RCEM is contributing. RCEM is responsible for setting standards of training, administering examinations and awarding Fellowship and Membership of the College as well as supporting Post Graduate Doctors in Training to qualify in the specialty of Emergency Medicine. The College works to ensure high quality patient care by setting and monitoring standards. We provide expert guidance and advice on health policy to relevant bodies on matters relating to Emergency Medicine and advocate and influence policy makers and politicians on behalf of our members and the wider specialty. It should be noted that RCEM does not have any statutory or regulatory role.”

Source location
Response from RCEM
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Issue updated clinical-governance guidance supporting supervision, board-level responsibility and local governance of physician associates and anaesthesia associates.

Verbatim wording from the response
“To support employers, we have issued our updated guidance Effective clinical governance to support revalidation. It emphasises that PAs and AAs must be supervised and recommends that organisations identify an individual at Board level to be responsible for PAs and AAs. It also suggests establishing local processes to govern how these professionals are deployed and supervised. The work of a PA or AA must be overseen by a named senior doctor, and they must work together to agree appropriate limitations to their practice.”

Source location
Response from General Medical Council
Page 4 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Provide feedback on specialist professional bodies’ draft guidance concerning physician associate scope of practice.

Verbatim wording from the response
“We believe that the royal colleges and other specialist professional bodies have the level of clinical expertise required to provide more detailed guidance on PA scope of practice within their specialty areas. We are grateful for the work that royal colleges have undertaken so far in developing”

Source location
Response from General Medical Council
Page 4 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Campaign with fellows and members to limit the pace and scale of physician-associate rollout until safe deployment systems are established.

Verbatim wording from the response
“Working with our fellows and members, the RCP will continue to actively campaign to limit the pace and scale of roll-out of PAs in the NHS until we are reassured that there are safe systems in place for PA deployment. We have repeatedly made clear that PAs are not doctors, and they cannot and must not replace doctors. We have also called on the UK government and the NHS to develop and publish an evidence-base and evaluation framework around the introduction of PAs. This should be a priority, and we are working with the RCP Patient Safety Committee to consider what more we can do to support this agenda.”

Source location
Response from Royal College of Physicians
Page 3 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Commission an independent review of Physician Associate and Anaesthesia Associate roles and their contribution to multidisciplinary healthcare teams.

Verbatim wording from the response
“This Government takes concerns about patient safety seriously. This is why, in November 2024, we commissioned ████████ to lead an independent review into PAs and AAs: Independent Review of the Physician Associate and Anaesthesia Associate - Hansard - UK Parliament. Whilst there are governance processes already in place for the Physician Associate (PA) and Anaesthesia Associate (AA) professions, the review will consider the safety of the roles and their contribution to multidisciplinary healthcare teams. The review will draw upon a range of national and international evidence to produce a comprehensive picture of the physician associate and anaesthesia associate roles. This will include published research, real world data, and patient and professional views.”

Source location
Response from DHSC
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Move Physician Associates to Tier 1 of the Emergency Department rota in line with updated national guidance.

Verbatim wording from the response
“The Trust has always followed national guidance regarding the scope of practice for Physician Associates. We recognise that PAs are not medically qualified, and we do not allow PAs to undertake roles outside of their competency, but they nonetheless have a valid role within the clinical team. Until February 2025 the Royal College of Emergency Medicine guidance was that in the Emergency Department Physician Associates should work on Tier 2 of the ED rota. That did not mean that PAs were the same as Tier 2 resident doctors, but that they could work alongside them. As of 28th February 2025, the Royal College of Emergency Medicine issued new guidance, stating that PAs should now be on Tier 1 of the ED rota. We immediately made that change and implemented the new guidance in full. We have issued a new scope of practice document for PAs in the ED which we have enclosed with this letter.”

Source location
Response from Surrey and Sussex NHS
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Issue and implement an Emergency Department Physician Associate scope of practice requiring senior doctor oversight, appropriate patient selection, escalation, and medical review before discharge or admission.

Verbatim wording from the response
“In response to the issues raised in this Inquest, and in response to the new guidance from the Royal College of Emergency Medicine, enclosed with this letter, we have issued a new scope of practice document for PAs in our ED and implemented it immediately, as of 3rd March 2025. This specifically states that it is planned for a patient to be discharged from ED after seeing a PA, that patient must first be reviewed in person by a senior ED doctor, Tier 4 or 5. All our PAs and ED Consultants have been instructed to follow this change and are supportive of it and the document has been circulated.”

Source location
Response from Surrey and Sussex NHS
Page 3 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Publish interim guidance for physician associates working in medical specialties.

Verbatim wording from the response
“We agree with this and the RCP has written published interim guidance for physician associates working in the medical specialties.”

Source location
Response from Royal College of Physicians
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Amend the local Physician Associate governance policy to reflect changes in national guidance and regulation.

Verbatim wording from the response
“The PA involved in Mrs Marking’s care has undertaken an extensive reflective practice review with a number of the ED Consultants and will include this in their annual appraisal. We have had a local governance policy in place for all PAs that work at the Trust since 2015. Within this we worked to all available national guidance at the time and have amended the”

Source location
Response from Surrey and Sussex NHS
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Public terminology, role understanding and second-opinion rights fall outside the regulatory scope.

Verbatim wording from the response
“We are unable to comment on this point due to it being outside of the remit of our regulatory scope. Please note that the General Medical Council is a Respondent and would be best placed to respond to this question.”

Source location
Response from CQC
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The General Medical Council is best placed to address public terminology, role understanding and second-opinion rights.

Verbatim wording from the response
“We are unable to comment on this point due to it being outside of the remit of our regulatory scope. Please note that the General Medical Council is a Respondent and would be best placed to respond to this question.”

Source location
Response from CQC
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Existing NICE and GMC standards require healthcare professionals to identify their role to patients, addressing role-identification concerns.

Verbatim wording from the response
“You highlight the limited awareness and understanding of the PA role and that the title is misleading. We are clear that an important part of being a healthcare professional is ensuring that the people they come into contact with understand who they are. All healthcare professionals should follow the National Institute for Health and Care Excellence (NICE) guidelines which state that healthcare professionals directly involved in a patient's care should introduce themselves and explain to their role to the patient.”

Source location
Response from DHSC
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
“Physician Associate” is a nationally sanctioned term describing healthcare professionals with recognised training, rather than an inherently misleading title.

Verbatim wording from the response
“The term ‘Physician Associate’ is misleading to the public: Mrs Marking’s son was under the mistaken belief that the Physician Associate was a doctor by this title in circumstances where no steps were taken by the Emergency Department or the Physician Associate to explain or clearly differentiate their role from that of medically qualified practitioners.”

Source location
Response from Surrey and Sussex NHS
Page 1 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The Trust considers that it has explained everything within its remit regarding patients’ and families’ ability to seek a second medical opinion.

Verbatim wording from the response
“The right of patients and family to seek a second opinion: The lack of public knowledge that a Physician Associate is not medically qualified has the potential to hinder requests by patients and their relatives who would wish to seek an opinion from a medical practitioner. It also raises issues of informed consent and protection of patient rights if the public are not aware or have not been properly informed that they are being treated by a Physician Associate rather than a medically qualified doctor.”

Source location
Response from Surrey and Sussex NHS
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The General Medical Council is responsible for regulating individual Physician Associates, rather than this regulator.

Verbatim wording from the response
“Whilst we have legal powers to regulate providers of health and social care, we do not have any powers to regulate individual practitioners, such as Physician Associates. That is the duty of the General Medical Council from 13 December 2024. Prior to this date, Physicians Associates were not regulated by a formal body. Physicians Associates are encouraged to join the General Medical Council’s register if already practising in the UK, however there is a transition period of two years, after which, Physicians Associates must legally be registered with the General Medical Council. (Links: NHS England » Update on physician associates and anaesthesia associates ahead of GMC regulation, Registration - GMC)”

Source location
Response from CQC
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Existing CQC guidance and provider governance, supervision and competence requirements apply to Physician Associates in secondary care.

Verbatim wording from the response
“The CQC guidance whilst written for Physician Associates in primary care, is largely applicable in secondary care settings too.”

Source location
Response from CQC
Page 3 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The College has no statutory or regulatory role in regulating physician associates.

Verbatim wording from the response
“The role and regulation of PAs has been subject to much comment in recent years [3], we note that there is an ongoing review into the safety and scope of the PA role [4] to which RCEM is contributing. RCEM is responsible for setting standards of training, administering examinations and awarding Fellowship and Membership of the College as well as supporting Post Graduate Doctors in Training to qualify in the specialty of Emergency Medicine. The College works to ensure high quality patient care by setting and monitoring standards. We provide expert guidance and advice on health policy to relevant bodies on matters relating to Emergency Medicine and advocate and influence policy makers and politicians on behalf of our members and the wider specialty. It should be noted that RCEM does not have any statutory or regulatory role.”

Source location
Response from RCEM
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Employers, clinical leaders and supervisors must determine PAs’ permitted activities and required supervision through local clinical governance.

Verbatim wording from the response
“Robust systems of clinical governance are important to ensure a consistent approach to the safe and effective deployment of PAs and AAs. Employers have a clinical governance responsibility to ensure that all their employees are appropriately trained and competent to do the activities they are tasked with. It is an employer’s responsibility, with the involvement of clinical leaders and supervisors, to determine which activities or specific tasks an individual can carry out and what level of supervision is required.”

Source location
Response from General Medical Council
Page 4 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Individual competence and clinical context vary, so GMC standards do not impose fixed ceilings on what registered PAs may do.

Verbatim wording from the response
“objectively by passing our two-part assessment. Our standards do not impose ceilings on what individual doctors, PAs and AAs can do once registered. This is because we recognise that competence will vary by individual and is shaped by their supervised training and experience, and the clinical context of their work.”

Source location
Response from General Medical Council
Page 4 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The GMC is responsible for regulating physician associates, while national system leaders should develop their scope of practice and supervision framework.

Verbatim wording from the response
“The RCP believes that PAs should be working to nationally-agreed guidelines and relying on local guidelines only risks inconsistency, or at worst no agreed guidelines at all. The GMC is now responsible for regulation, but our understanding is that regulation will need to be supported by national guidelines to provide a clear framework for assessment. We would also welcome clarity of PA clinical competency at qualification; we note passing the PA exit exam is not synonymous with competency and ability in a clinical setting.”

Source location
Response from Royal College of Physicians
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
GMC regulation and existing NHS guidance already govern PA regulation, competence, scope, supervision and employer clinical governance.

Verbatim wording from the response
“Regulation of PAs and AAs by the General Medical Council (GMC) began in December 2024. The GMC expects the vast majority of practising PAs and AAs to join the register within the first six months of regulation, and they will be required to do so within two years of regulation commencing. PAs and AAs who are registered with the General Medical Council (GMC) are required to follow the professional standards and behaviour set out in Good medical practice. This includes introducing themselves and their role in patient care.”

Source location
Response from DHSC
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Existing national guidance, local governance policy and competency frameworks are considered sufficient to keep Physician Associates within their scope of practice.

Verbatim wording from the response
“The Trust has always followed national guidance regarding the scope of practice for Physician Associates. We recognise that PAs are not medically qualified, and we do not allow PAs to undertake roles outside of their competency, but they nonetheless have a valid role within the clinical team. Until February 2025 the Royal College of Emergency Medicine guidance was that in the Emergency Department Physician Associates should work on Tier 2 of the ED rota. That did not mean that PAs were the same as Tier 2 resident doctors, but that they could work alongside them. As of 28th February 2025, the Royal College of Emergency Medicine issued new guidance, stating that PAs should now be on Tier 1 of the ED rota. We immediately made that change and implemented the new guidance in full. We have issued a new scope of practice document for PAs in the ED which we have enclosed with this letter.”

Source location
Response from Surrey and Sussex NHS
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Monitoring or accrediting physician associate training is outside the College’s responsibility.

Verbatim wording from the response
“RCEM is not responsible for monitoring or accrediting PA training.”

Source location
Response from RCEM
Page 2 · response
Published 26 February 2025
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Royal colleges and specialist professional bodies should provide detailed specialty-specific guidance on physician associate scope of practice.

Verbatim wording from the response
“We believe that the royal colleges and other specialist professional bodies have the level of clinical expertise required to provide more detailed guidance on PA scope of practice within their specialty areas. We are grateful for the work that royal colleges have undertaken so far in developing”

Source location
Response from General Medical Council
Page 4 · response
Published 26 February 2025
Open published response
31 Jul2024
Manchester North
Concerns raised5
1. Failure to ensure clear identification and understanding of the Physician Associate role
2. Lack of a clear mechanism for reporting concerns about individual Physician Associates
3. Failure to require employers to verify Physician Associate registration
1. Lack of regulatory oversight of Physician Associates
2. Lack of a national framework for training, supervision and competence of Physician Associates
This report raised 1 other concern. They are not shown here because they do not form part of this recurring concern.
Responses linked to these concerns
Each statement is shown once, even when linked to more than one concern.
Actions described in response 23
1. Action
  Publish guidance for introducing physician associates and explaining their role to patients, supervisors, employers and healthcare organisations.
  Stated by Faculty of Physician AssociatesStated completed
2. Action
  Continue working with stakeholders to improve communication of physician associates’ roles and responsibilities to colleagues, patients and the public.
  Stated by Faculty of Physician AssociatesStated in progress
3. Action
  Continue campaigning to limit the pace and scale of physician associate rollout until safe deployment systems are established.
  Stated by Royal College of PhysiciansStated in progress
1. Action
  Develop, consult on, revise, approve and publish guidance on safe and effective practice for employing physician associates.
  Stated by Royal College of PhysiciansStated in progress
2. Action
  Work with fellows, members and the Patient Safety Committee to consider further support for evidence and evaluation of physician associate deployment.
  Stated by Royal College of PhysiciansStated in progress
3. Action
  Implement alphabetical prefixes and prominent profession-type labelling on public-facing registers for physician associates and anaesthesia associates.
  Stated by General Medical CouncilStated planned
4. Action
  Share the physician associate code of conduct and publish the procedure for raising and adjudicating complaints.
  Stated by Faculty of Physician AssociatesStated completed
5. Action
  Remind employers to check physician associates’ voluntary register before employment and at regular intervals.
  Stated by Faculty of Physician AssociatesStated completed
6. Action
  Begin statutory regulation of physician associates and anaesthesia associates from December 2024.
  Stated by General Medical CouncilStated planned
7. Action
  Strongly encourage physician associates to join the GMC register as soon as possible.
  Stated by General Medical CouncilStated planned
8. Action
  Campaign for regulation of physician associates.
  Stated by Royal College of PhysiciansStated completed
9. Action
  Meet regularly with the General Medical Council on physician associate regulation and post-regulation arrangements.
  Stated by Royal College of PhysiciansStated in progress
10. Action
  Respond to the General Medical Council consultation on physician associate regulation, raising patient-safety concerns.
  Stated by Royal College of PhysiciansStated completed
11. Action
  Consider consultation responses and finalise the rules, professional standards and guidance required to implement associate regulation.
  Stated by General Medical CouncilStated in progress
12. Action
  Work with royal colleges and specialist societies to develop physician associate career pathways and guidance for safe deployment within multidisciplinary teams.
  Stated by Faculty of Physician AssociatesStated in progress
13. Action
  Maintain a standardised national physician associate curriculum aligned with GMC outcomes for education and qualification.
  Stated by Faculty of Physician AssociatesStated completed
14. Action
  Provide qualified physician associates with an e-Portfolio containing workplace-based, supervised learning and procedural skills assessment forms.
  Stated by Faculty of Physician AssociatesStated completed
15. Action
  Publish advice for doctors supervising physician associates and update the clinical governance handbook on their deployment and supervision.
  Stated by General Medical CouncilStated completed
16. Action
  Publish guidance supporting physician associate students and course providers pending implementation of statutory regulation.
  Stated by General Medical CouncilStated completed
17. Action
  Require course providers to update syllabuses and assessments, and check those changes through the education quality assurance process.
  Stated by General Medical CouncilStated in progress
18. Action
  Finalise updated guidance for physician associate students on professional standards and the process for approving curricula.
  Stated by General Medical CouncilStated in progress
19. Action
  Support royal colleges’ development of supervision and competency guidance, while encouraging consistent alignment across guidance produced by colleges and NHS employers.
  Stated by General Medical CouncilStated in progress
20. Action
  Approve physician associate courses and curricula once regulation begins, ensuring they meet required clinical knowledge and skills standards.
  Stated by General Medical CouncilStated planned
Respondent positions 6
1. Position
  Responsibility for distinct uniforms to help patients distinguish professionals rests with the NHS and employers.
  Stated by General Medical CouncilRedirects responsibility
1. Position
  System leaders, including the GMC, should lead development and oversight of a national physician associate scope of practice.
  Stated by Royal College of PhysiciansRedirects responsibility
2. Position
  The GMC currently has no power to investigate concerns about physician associates because they are not yet regulated by it.
  Stated by General Medical CouncilOutside remit
3. Position
  The GMC has no role in determining the investigatory or disciplinary processes of the Faculty of Physician Associates’ voluntary register.
  Stated by General Medical CouncilOutside remit
4. Position
  The FPA cannot mandate physician-associate registration because it has no regulatory powers.
  Stated by Faculty of Physician AssociatesUnable to act
5. Position
  Regulatory oversight of physician associates falls outside the organisation’s role because it is not a regulatory body.
  Stated by Royal College of PhysiciansOutside remit
AI-generated summary

Susan Pollitt · Prevention of Future Deaths report

This summary was generated using AI from the published report. Please read the original report for the complete account.

Report summary

Susan Pollitt was admitted to hospital after collapsing at home and developed ascites during her admission. An ascitic drain was inserted, remained in place for 21 hours, and was clamped; she developed bacterial peritonitis and died on 16 July 2023. The principal concerns included the lack of regulatory oversight and national training and competency frameworks for Physician Associates, and limited understanding of their role and responsibilities in managing ascitic drains.

Read the report on judiciary.uk
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Failure to ensure clear identification and understanding of the Physician Associate role
Wider context from the report
“4. There remains limited understanding and awareness of the role of a Physician Associate both amongst medical colleagues, patients and their families. The lack of a distinct uniform and the title “Physician” gives rise to confusion as to whether the practitioner is a doctor. ”
Source location
Susan Pollitt · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Lack of a clear mechanism for reporting concerns about individual Physician Associates
Wider context from the report
“2. The Physicians Associate Managed Voluntary Register held by the Faculty of Physician Associates (FPA) is voluntary. Whilst employers are encouraged to check the register there is no duty to do so, nor is it clear how the FPA would be made aware of any concerns relating to an individual Physician Associate. ”
Source location
Susan Pollitt · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Failure to require employers to verify Physician Associate registration
Wider context from the report
“2. The Physicians Associate Managed Voluntary Register held by the Faculty of Physician Associates (FPA) is voluntary. Whilst employers are encouraged to check the register there is no duty to do so, nor is it clear how the FPA would be made aware of any concerns relating to an individual Physician Associate. ”
Source location
Susan Pollitt · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Lack of regulatory oversight of Physician Associates
Wider context from the report
“1. There is no regulatory body with oversight of Physician Associates. It is understood that this is currently the subject of a consultation by the General Medical Council. ”
Source location
Susan Pollitt · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence
How this individual concern was interpreted
PFD Monitor created a concise, searchable interpretation from the report wording shown below.
PFD Monitor interpretation
Lack of a national framework for training, supervision and competence of Physician Associates
Wider context from the report
“3. There is no national framework as to how Physician Associates should be trained, supervised and deemed competent. This is placing both patients, Physicians Associates and their employers at risk. The Court heard that since the death of Mrs Pollitt the Northern Care Alliance have put in place a local trust framework. Unlike all other clinical roles there is no national guidance save for very recent guidance issued by the British Medical Association (March 2024). ”
Source location
Susan Pollitt · Prevention of Future Deaths report
Page 2 · concerns
Open source report
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Publish guidance for introducing physician associates and explaining their role to patients, supervisors, employers and healthcare organisations.

Verbatim wording from the response
“In October 2023, the FPA published titles and introduction guidance for PAs, supervisors, employers and organisations. The guidance was drawn up with a multi-professional panel of stakeholders, including representation from the RCP PCN, to clarify the role of a PA within a multidisciplinary team. The aim is to ensure appropriate introductions to patients and explanation of the role, particularly highlighting that PAs are not doctors. We recognise that there is a continued need to inform the public, healthcare services and the clinical professions on the role and remit of physician associates.”

Source location
Response from Faculty of Physician Associates
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Continue working with stakeholders to improve communication of physician associates’ roles and responsibilities to colleagues, patients and the public.

Verbatim wording from the response
“We agree that there should be a national public and patient information campaign to create better awareness of the PA role. We will continue to work with other stakeholders, including the RCP Patient and Carer Network (PCN), to improve how we communicate the role and responsibilities of PAs. We welcome the opportunity to work collaboratively with others on this.”

Source location
Response from Faculty of Physician Associates
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Continue campaigning to limit the pace and scale of physician associate rollout until safe deployment systems are established.

Verbatim wording from the response
“Following a vote of the RCP fellowship, the RCP is now calling for a limit in the pace and scale of the roll-out of PAs. We have called on NHS England to review its projections for growth for the PA role as set out in the 2023 NHSE Long Term Workforce Plan.”

Source location
Response from Royal College of Physicians
Page 1 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Develop, consult on, revise, approve and publish guidance on safe and effective practice for employing physician associates.

Verbatim wording from the response
“The RCP is developing draft guidance on safe and effective practice for employing PAs. The college recently carried out an external stakeholder consultation on the first draft of this guidance. Work is now taking place to review the consultation feedback, refresh the draft guidance, consider how fellows and members should be consulted, and take the final guidance to RCP Council for sign-off and publication by the end of 2024.”

Source location
Response from Royal College of Physicians
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Work with fellows, members and the Patient Safety Committee to consider further support for evidence and evaluation of physician associate deployment.

Verbatim wording from the response
“Working with our fellows and members, the RCP will continue to actively campaign to limit the pace and scale of roll-out of PAs in the NHS until we are reassured that there are safe systems in place for PA deployment. We have repeatedly made clear that PAs are not doctors, and they cannot and must not replace doctors. We have also called on the UK government and the NHS to develop and publish an evidence base and evaluation framework around the introduction of PAs. This should be a priority, and we are working with the RCP Patient Safety Committee to consider what more we can do to support this agenda.”

Source location
Response from Royal College of Physicians
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Implement alphabetical prefixes and prominent profession-type labelling on public-facing registers for physician associates and anaesthesia associates.

Verbatim wording from the response
“In March this year we also announced that we would implement an alphabetical prefix for PA and AA GMC reference numbers and ensure the prominent labelling of profession type on our public-facing registers. This means that in future when patients search our registers it will be very clear whether an individual is a doctor, a PA or an AA not only because of the use of a prefix for PAs and AAs but also because the face of the register will actually spell out in full the professional title of each individual (‘Doctor’, ‘Physician Associate’, ‘Anaesthesia Associate’).”

Source location
Response from GMC
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Share the physician associate code of conduct and publish the procedure for raising and adjudicating complaints.

Verbatim wording from the response
“The FPA code of conduct is regularly shared with FPA members. Should an employer, patient or others have a complaint about a PA, they can advise the FPA through emailing ████████. The FPA website sets out the complaints procedure here. Attached is the process to adjudicate complaints.”

Source location
Response from Faculty of Physician Associates
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Remind employers to check physician associates’ voluntary register before employment and at regular intervals.

Verbatim wording from the response
“This statement highlights why formal regulation is so important. Neither the RCP nor the FPA has regulatory powers to mandate registration. In the absence of this, the FPA writes to employers on a regular basis reminding them of the existence of the PAMVR and, importantly, of the need to check that a PA is registered on the PAMVR before employment, as well as checking at regular intervals during their employment.”

Source location
Response from Faculty of Physician Associates
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Begin statutory regulation of physician associates and anaesthesia associates from December 2024.

Verbatim wording from the response
“In 2017, the Department of Health and Social Care (DHSC) consulted on which healthcare regulator would be most suitable to regulate one, some, or all the medical associate professions, which include PAs and AAs. Surgical care practitioners are the third profession in this group but are not included in those we will regulate. Following the consultation, the Government determined the GMC was most appropriate and formally asked us to take on the regulation of PAs and AAs which we agreed to do. The UK and Scottish parliaments approved the legislation (Anaesthesia Associates and Physician Associates Order 2024) earlier this year and it has been granted Royal Assent. This means the GMC will become the regulator of PAs and AAs from December 2024 and, from December 2026, they will have protected titles in law (‘Physician Associate’ and ‘Anaesthesia Associate’).”

Source location
Response from GMC
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Strongly encourage physician associates to join the GMC register as soon as possible.

Verbatim wording from the response
“We anticipate that employers will make GMC registration a condition for their PAs in the same way as they have done up to now in relation to voluntary registration. Although GMC registration doesn’t become a legal requirement for practice until December 2026, we will strongly encourage all PAs to join our register as soon as possible.”

Source location
Response from GMC
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Campaign for regulation of physician associates.

Verbatim wording from the response
“In the interests of patient safety, the RCP has campaigned for over 5 years for the regulation of PAs. It has been a long and unpredictable journey that will finally see the majority of regulatory provisions come into force in December 2024.”

Source location
Response from Royal College of Physicians
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Meet regularly with the General Medical Council on physician associate regulation and post-regulation arrangements.

Verbatim wording from the response
“████████ who is acting as RCP president, and ████████ chair of the PAOG, continue to meet regularly with the GMC. We have written to NHS England to ask whether they intend to review the projections for growth in the PA workforce. Both the GMC and NHS England will attend an RCP Council meeting in November 2024 to discuss the post-regulation landscape for PAs.”

Source location
Response from Royal College of Physicians
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Respond to the General Medical Council consultation on physician associate regulation, raising patient-safety concerns.

Verbatim wording from the response
“We responded to the GMC consultation on the regulation of PAs earlier this year, raising concerns around the content of the curricula for PA and anaesthesia associate (AA) postgraduate studies, issues around prescribing and medicines safety, the capacity of supervisors, and the impact of the PA role on training opportunities for resident doctors.”

Source location
Response from Royal College of Physicians
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Consider consultation responses and finalise the rules, professional standards and guidance required to implement associate regulation.

Verbatim wording from the response
“We recently consulted on the rules, standards and guidance needed to implement the legislation that gives us the power to regulate PAs and we’re now considering the responses so that we can finalise our approach. Once regulation begins, we will have powers to:”

Source location
Response from GMC
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Work with royal colleges and specialist societies to develop physician associate career pathways and guidance for safe deployment within multidisciplinary teams.

Verbatim wording from the response
“The FPA and its members are actively involved in writing PA-related guidance with medical royal colleges, academies and specialist societies and we want to help increase understanding of our role. We recognise that there are concerns about the lack of a post-qualification national career development and competency framework for physician associates. We are working with medical royal colleges and specialist societies as they develop their own pathways, including guidance of how PAs can be safely and effectively deployed within MDTs.”

Source location
Response from Faculty of Physician Associates
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Maintain a standardised national physician associate curriculum aligned with GMC outcomes for education and qualification.

Verbatim wording from the response
“The draft PA curriculum sets out guidance on the competencies expected from a newly qualified physician associate. This national higher education institutions (HEIs) across all four UK nations with a standardised framework to ensure high-quality education for PA students. It is owned by the FPA and has been aligned to the GMC’s generic and shared outcomes for PAs and anaesthesia associates.”

Source location
Response from Faculty of Physician Associates
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Provide qualified physician associates with an e-Portfolio containing workplace-based, supervised learning and procedural skills assessment forms.

Verbatim wording from the response
“There is currently no national framework for post-qualification competencies (including procedures). PAs increase their clinical skills and competencies post-qualification similarly to other healthcare professionals. The FPA e-Portfolio was launched in October 2023 for qualified PAs and uses workplace-based assessment (WBPA) or supervised learning event (SLE) forms. This also includes Direct Observation of Procedural Skills (DOPS) forms, which were first made available to FPA members in October 2021.”

Source location
Response from Faculty of Physician Associates
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Publish advice for doctors supervising physician associates and update the clinical governance handbook on their deployment and supervision.

Verbatim wording from the response
“We have also published our own advice for doctors who supervise PAs, and earlier this year we updated our clinical governance handbook to set out our expectation that organisations who employ PAs should make appropriate arrangements for their deployment and supervision.”

Source location
Response from GMC
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Publish guidance supporting physician associate students and course providers pending implementation of statutory regulation.

Verbatim wording from the response
“Regarding PA education and training - once regulation begins in December 2024, we’ll have powers to set the standards for course providers and regularly check that they’re being met. We have already published a range of guidance to support PAs student PAs and course providers pending the implementation of regulation. From December 2024 we will be able to formally approve courses and curricula to ensure that PAs will have the clinical knowledge and skills needed to work safely once they qualify.”

Source location
Response from GMC
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Require course providers to update syllabuses and assessments, and check those changes through the education quality assurance process.

Verbatim wording from the response
“In preparation for the start of regulation we have already asked course providers to update their courses, including their syllabus and assessments, using the relevant curriculum as a guide, and we are checking that this has been done through our education quality assurance process. We are also finalising updated guidance for PA students on professional standards and the process for approving PA curricula.”

Source location
Response from GMC
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Finalise updated guidance for physician associate students on professional standards and the process for approving curricula.

Verbatim wording from the response
“In preparation for the start of regulation we have already asked course providers to update their courses, including their syllabus and assessments, using the relevant curriculum as a guide, and we are checking that this has been done through our education quality assurance process. We are also finalising updated guidance for PA students on professional standards and the process for approving PA curricula.”

Source location
Response from GMC
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Support royal colleges’ development of supervision and competency guidance, while encouraging consistent alignment across guidance produced by colleges and NHS employers.

Verbatim wording from the response
“Finally, we have been supporting the work that individual royal colleges, and the Academy of Medical Royal Colleges, are currently leading on developing a range of guidance on supervision and how PAs can safely develop their skills and competencies over time once they have qualified and registered with us. The Royal College of Physicians is also concentrating on their guidance and the Royal College of General Practitioners plans to do so shortly. We are also encouraging colleges, NHS employers and others to ensure that all guidance being produced is aligned and consistent so as not to cause confusion for employers, supervisors or PAs themselves.”

Source location
Response from GMC
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent action was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Approve physician associate courses and curricula once regulation begins, ensuring they meet required clinical knowledge and skills standards.

Verbatim wording from the response
“Regarding PA education and training - once regulation begins in December 2024, we’ll have powers to set the standards for course providers and regularly check that they’re being met. We have already published a range of guidance to support PAs student PAs and course providers pending the implementation of regulation. From December 2024 we will be able to formally approve courses and curricula to ensure that PAs will have the clinical knowledge and skills needed to work safely once they qualify.”

Source location
Response from GMC
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Responsibility for distinct uniforms to help patients distinguish professionals rests with the NHS and employers.

Verbatim wording from the response
“The issue you raise about the need for distinct uniforms to help patients distinguish between professionals is for the NHS and employers to address.”

Source location
Response from GMC
Page 4 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
System leaders, including the GMC, should lead development and oversight of a national physician associate scope of practice.

Verbatim wording from the response
“A comprehensive, national, safe and clear scope of clinical practice for PAs is essential. However, we note the following:”

Source location
Response from Royal College of Physicians
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The GMC currently has no power to investigate concerns about physician associates because they are not yet regulated by it.

Verbatim wording from the response
“I will leave it to the FPA to explain how they currently deal with concerns raised about a member of their voluntary register. The GMC currently has no power to investigate concerns raised about PAs as they are not yet regulated by us, and we have no role in determining the investigatory and disciplinary processes of the FPA. However, we can and will look at any outstanding concerns about an individual PA’s fitness to practise when considering their application for registration with us from December this year.”

Source location
Response from GMC
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The GMC has no role in determining the investigatory or disciplinary processes of the Faculty of Physician Associates’ voluntary register.

Verbatim wording from the response
“I will leave it to the FPA to explain how they currently deal with concerns raised about a member of their voluntary register. The GMC currently has no power to investigate concerns raised about PAs as they are not yet regulated by us, and we have no role in determining the investigatory and disciplinary processes of the FPA. However, we can and will look at any outstanding concerns about an individual PA’s fitness to practise when considering their application for registration with us from December this year.”

Source location
Response from GMC
Page 3 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
The FPA cannot mandate physician-associate registration because it has no regulatory powers.

Verbatim wording from the response
“This statement highlights why formal regulation is so important. Neither the RCP nor the FPA has regulatory powers to mandate registration. In the absence of this, the FPA writes to employers on a regular basis reminding them of the existence of the PAMVR and, importantly, of the need to check that a PA is registered on the PAMVR before employment, as well as checking at regular intervals during their employment.”

Source location
Response from Faculty of Physician Associates
Page 2 · response
Published 8 August 2024
Open published response
Source evidence

How this respondent position was interpreted

PFD Monitor created a concise, searchable interpretation from the published response wording shown below.

PFD Monitor interpretation
Regulatory oversight of physician associates falls outside the organisation’s role because it is not a regulatory body.

Verbatim wording from the response
“The RCP has confirmed that the FPA will close in December, along with the PAMVR. The initial transfer of PAMVR data from the RCP to the GMC will begin on 31 October 2024. The GMC register will open on 13 December 2024, when regulation begins, but will continue to be voluntary for the first two years. The PAMVR will remain static, but searchable, until 31 March 2025 when it will be closed.”

Source location
Response from Royal College of Physicians
Page 2 · response
Published 8 August 2024
Open published response

Data last updated 7 September 2026

What this concern includes

Not included

Reports over time

Concerns raised5

Failure to clearly explain and differentiate the Physician Associate role from medically qualified practitioners

Failure to inform patients and families that Physician Associates are not medically qualified

Lack of public understanding of the Physician Associate role

Failure to prevent Physician Associates undertaking roles outside their competency

Lack of regulated scope-of-practice guidance and recognised training for Physician Associates

Actions described in response An action is something a respondent says it has done, is doing, or plans to do in response to the concern raised.18

Respondent positions A position is what a respondent says about the concern when they do not describe a specific action.15

Actions described in response 18

Respondent positions 15