Request for Review and Clarification of the RCGP’s Scope of Practice Guidance on Physician Associates in Primary Care

Written by UMAPs Ltd

October 28, 2024

Dear RCGP Council & Trustees, 

We write on behalf of United Medical Associate Professionals (UMAPs) to address critical concerns regarding the RCGP’s recent guidance on the scope of practice for Physician Associates (PAs) in primary care. This guidance has raised substantial questions regarding evidence, procedural neutrality, and the wide-reaching detriments already affecting PAs. As an organisation representing the PA profession, we urge the RCGP to review and amend the guidance, ensuring an evidence-based and impartial approach to professional advocacy. 

1. Clarifying the RCGP Guidance’s Legal Standing 

The RCGP’s guidance implies an authoritative stance that has led to significant misinterpretations. Many employers view this document as binding, which has precipitated unnecessary changes in PA roles and undermined their standing within general practice teams. To clarify, RCGP guidance does not hold statutory authority, nor is it legally enforceable. Employers and NHS bodies should not perceive this guidance as justification for disciplinary measures or terminations. We respectfully urge the RCGP to incorporate language explicitly stating that this document serves as advisory guidance only. Additionally, as College membership is not mandatory for general practitioners, we have observed Fellows resigning in protest of hostile behaviour towards another profession. This further raises questions about how this guidance impacts PA employment across practices where the RCGP may not reflect all viewpoints. 

2. Concerns Regarding Survey Data Integrity 

UMAPs is concerned with the reliability of the data underpinning the RCGP’s conclusions on patient safety related to PAs. On 26/04/2024, we presented evidence to the RCGP showing that the “Doctors Vote” group had coordinated a campaign on Reddit, instructing participants on how to complete the RCGP survey negatively regarding PA roles. This orchestration raises serious questions about the survey’s objectivity and the extent to which responses were influenced rather than based on actual experience. In fact, the survey itself indicates that 44% of respondents had never worked with a PA, further undermining the credibility of any patient safety claims derived from this data. 

Moreover, UMAPs has documented numerous instances of survey manipulation designed to sway institutional decisions unfairly. Such incidents compromise the impartiality expected from an evidence-led organization and threaten to damage inter-professional relations. 

3. Clarification on NHS Resolution’s Indemnity Position for PAs 

The RCGP’s guidance implies that PAs may face indemnity issues under NHS schemes. In response to an inquiry from UMAPs, NHS Resolution clarified on 23/10/2024: 

“Cover under the Clinical Negligence Scheme for General Practice (CNSGP) is linked to the form of contract the services are provided under. CNSGP covers NHS activities which are commissioned under a GMS, PMS or APMS contract or as enhanced primary care elements under Schedule 2L of the NHS Standard Contract (each a “Primary Care Contract”). Cover also extends to services that are delivered under a direct sub-contract to a Primary Care Contract. Cover under the CNSGP scheme will be dependent on whether a contract is in place with the NHS to provide the services and the type of contract the service is provided under. 

If Physician Associates are providing the service under a Primary Care Contract (as above) or a direct sub-contract of a Primary Care Contract, then all those providing the service will be eligible for cover under CNSGP. 

If the services are not being provided under a Primary Care Contract, or a direct sub-contract to a Primary Care Contract, the services may still be covered as an ancillary health service under CNSGP if you can answer ‘yes’ to the following: 

(1) Are you carrying out an activity that consists of, or is in connection with, the provision of NHS services? 

(2) Are those NHS services being provided by, or under a contract with, a person or organisation whose principal activity is to provide primary care under a Primary Care Contract? 

(3) Is the activity in question connected to the diagnosis, care or treatment of a patient?” 

This communication indicates that CNSGP coverage applies when PAs are working under a Primary Care Contract or its direct subcontract. As such, the RCGP’s assertion about indemnity should be reconsidered or updated to prevent misleading employers and to maintain trust in the indemnity protections provided for PAs within primary care settings. 

4. Potential Conflicts of Interest 

Given the significant economic and professional impact of this guidance on PAs, we request information on any conflicts of interest declared by RCGP Council members who voted on this guidance. Specifically, we seek clarification on the number of members involved in: 

  • Private practice, 
  • Locum (sessional GP) work, or 
  • Affiliations with the Doctors Vote or BMA initiatives opposed to PA roles. 

Given the gravity of the decision, it is crucial for transparency and procedural integrity that any financial or associative interests were declared and documented before the vote. Additionally, we request information on how these potential conflicts were managed to ensure a fair and unbiased outcome. Should there have been a lack of such disclosures, we ask that the RCGP outlines how it will address this oversight to restore confidence in its decision-making processes. 

5. Wide-reaching Impact on Patient Access and PA Wellbeing 

The effects of this guidance extend beyond economic detriments to PAs; it has implications for patient care and NHS stability. PAs play a crucial role in reducing patient wait times, addressing care gaps, and ensuring timely diagnoses. In practices where PAs’ roles have been restricted or terminated, patients now face longer wait times, potentially delayed diagnoses—including for cancer—and the re-introduction of costly locum cover. Some practices are again forced to rely on locum GPs at significant cost, up to £14,000 per month, when salaried PAs were readily filling these needs. This guidance risks reducing patient access to care, increasing GP partner workloads, and adding financial strain to practices. 

6. Request for Immediate Remedial Action 

UMAPs formally requests that the RCGP: 

  • Revises its guidance to clarify the advisory, non-binding nature of the document. 
  • Publicly amends any statements implying indemnity limitations, in line with NHS Resolution’s stance on CNSGP coverage. 
  • Conducts a transparent review of the conflicts of interest disclosures from the relevant votes, including affiliations with private, locum, and Doctors Vote-related interests. 
  • Takes steps to establish a robust methodology for data collection that prevents manipulation and reflects a balanced representation of PAs’ safety and contributions in primary care. 

UMAPs remains committed to working collaboratively with all stakeholders to ensure a transparent, safe, and respectful work environment for all healthcare professionals. We look forward to a constructive response from the RCGP that addresses these critical concerns. 

Sincerely, 
PA Stephen Nash 
Acting General Secretary 
Chief Executive UMAPs LTD 
On Behalf of UMAPs Acting National Executive Committee 
United Medical Associate Professionals 

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