I am writing from the non-profit campaigning organisation EveryDoctor. We have been encouraging our network of NHS staff and patients to fill in your online public consultation into the regulation of physician associates (PAs) and anaesthesia associates (AAs). Many people within our network have considerable concerns about the drive to hire thousands of PAs and AAs at a time when there is chronic NHS understaffing, and millions of patients are struggling to access timely treatment in the NHS.

Many people are keen to contribute to your public consultation, but we are now hearing from those who are struggling to do so. The supporting documentation is lengthy and complicated, many find the questions in the actual survey obtuse and difficult to answer, and we have received emails from those with significant health problems who are finding that the structure of your consultation is presenting a barrier which is preventing them from contributing to your public consultation. I’m sure you will agree that this is deeply concerning.

Because of this, we are enabling those within our network to countersign the feedback that the EveryDoctor team has already sent to the GMC. We trust that their signatures and associated support for our concerns will be taken seriously by the GMC team as part of your public consultation.

Here is the summary of EveryDoctor’s feedback, which is supported by all of those who are signing this letter:

"To: Richard Marchant, Assistant Director of Regulation Policy, General Medical Council

Dear Sir,

I am writing from the organisation EveryDoctor, to contribute to your public consultation about the regulation of physician associates (PAs) and anaesthesia associates (AAs). We are encouraging doctors and others within our network to fill in your consultation survey, but they have also been sharing more general feedback with us, and we wanted to pass this on.

Feedback about your online consultation:

1. Doctors and other healthcare workers are keen to provide input for your consultation, as it is extremely important. However, frontline healthcare staff are extremely busy and there have been concerns that reading the relevant material and then completing the survey is very time-consuming. This may limit the number of responses you receive.

2. There have been concerns that it is difficult to answer the questions you have posed within the consultation; we have been told that the questions are confusing or feel obscure.

More general feedback about physician associates and anaesthesia associates:

1. There are significant concerns from many doctors about the supervision of PAs and AAs. Specifically, many doctors are concerned because they do not have enough time to supervise physician associates closely, and yet are expected to take responsibility to do so/ sign prescriptions etc.

2. There are questions about induction for PAs/AAs. Doctors would like to know that these members of staff have core training/ competencies signed off before they are allowed to perform these.

3. How can the training competencies be standardised? At present, we are hearing feedback that there is wide variation in competence between different PAs and AAs.

4. Doctors have expressed to us that they feel it is only appropriate for PAs and AAs to be supervised by senior doctors, not junior doctors.

5. There are questions about proximity – will a supervisor of a PA/ AA be in the same room/ corridor/ building, in order to provide sufficient oversight of their work?

6. What is the frequency of supervision that will be given by the PA/AA supervisor? Will they provide supervision after every patient/ every hour/ every clinic?

7. What is the acceptable ratio of supervisors to PAs/AAs? It is important that each supervisor has enough time/capacity to properly supervise the PA/AAs.

8. How will the supervision of PAs/AAs be written into the job plans of the doctors providing this role? How much time will be allocated?

9. Identifiers- it needs to be clear to the public which member of staff is a doctor, which is not a doctor, and what each role involves.

10. What will be displayed on the GMC register regarding the qualifications of PAs/ AAs, compared to the display for doctors?

11. There are significant concerns from doctors around the high rates of referrals for BAME doctors. How will the GMC manage this situation going forward both for doctors, and for PAs/AAs?

12. Will the PAs/AAs have career progression clearly set out? There is some confusion around their postgraduate training, and what this will mean in terms of their role within the workplace.

Yours sincerely

Dr Julia Patterson, Chief Executive, EveryDoctor"