The British Geriatrics Society welcomes the Department of Health’s consultation on the regulation of medical associate professions in the UK and the positive recognition of the medical associate role that it represents.
The British Geriatrics Society (BGS) is the professional body of specialists in the healthcare of older people in the United Kingdom. Our membership is drawn from doctors, nurses, allied health professionals and others with a particular interest in the care of older people and the promotion of better health in old age. Our vision is for a society where all older people receive high quality, patient-centred care when and where they need it. This informs and underpins all of the comments in our consultation response.
What level of professional assurance do you think is appropriate for PAs?
Statutory regulation
Physician Associates have a key role to play in helping to ensure that all patients, and in particular older people, have access to timely and appropriate healthcare that supports a person-centred approach and delivers positive health outcomes.
Our view is that statutory regulation is the best option for the regulation of Physician Associates. We believe that it is the most effective way of ensuring accountability and managing the risks associated with this complex role, the success of which relies in part on appropriate levels of supervision and oversight from Doctors. We also view statutory regulation as integral to the development of public understanding of and confidence in the role of physician associates.
What level of professional assurance do you think is appropriate for PA(A)s?
Statutory regulation
We consider statutory regulation for all categories of medical associates to be the best option. In addition to providing a higher level of public accountability, it would help to promote cohesion across the medical associate workforce.
What level of professional assurance do you think is appropriate for SCPs?
Statutory regulation
We consider statutory regulation for all categories of medical associates to be the best option. In addition to providing a higher level of public accountability, it would help to promote cohesion across the medical associate workforce.
What level of professional assurance do you think is appropriate for ACCPs?
Statutory regulation
We consider statutory regulation for all categories of medical associates to be the best option. In addition to providing a higher level of public accountability, it would help to promote cohesion across the medical associate workforce.
In the future, do you think that the expansion of medicines supply, administration mechanisms and/or prescribing responsibilities to any or all of the four MAP roles should be considered?
Yes
It would be of benefit to both patients and clinicians if all medical associates were to be authorised as independent prescribers, provided they are registered to prescribe. The positive impact this would have in terms of speeding up access to medications, as well as to the efficient use of staff time mean that we are in favour of independent prescribing. However, this must be within a healthcare system that has enough resources to ensure sufficient oversight and control, and clear lines of accountability. A potential concern we have is the risk of an over-reliance on physician associates, which would need to be monitored carefully if they are given independent prescribing responsibilities. Already the RCP Census 2016 shows that Physician Associates were seen more frequently in specialties with significant rota gaps.
We think that it is important that there is a joined-up approach to regulation, and that there needs to be strategic oversight of the ways in which the relatively new medical associate posts are being used in environments where the workforce is very stretched. Respecting and maintaining the boundaries of the role is key. We would like to see collaboration between the General Medical Council (if they become the regulator), Health Improvement, and the CQC to ensure that the vision behind the medical associate roles is implemented and monitored effectively.
Which healthcare regulator should have responsibility for the regulation of any or all of the four MAP roles?
General Medical Council
We have considered the potential benefits and dis-benefits of different levels of professional assurance. Our view is that it would be unhelpful to have different regulators for the different associate roles: a cohesive workforce, working in multidisciplinary teams is at the heart of good quality healthcare for older people and we therefore consider a single regulator to be the best approach to regulation.
A single regulator would also promote consistency of standards and quality assurance, as well as promoting public confidence in and understanding of the role of medical associates. Given the likelihood of the MA role expanding significantly in the next few years we think it is important that statutory regulation by a single regulator is established at an early date. Our view is that this regulatory function should be carried out by the General Medical Council.
Do you agree or disagree with the costs and benefits of the different types of regulation identified above. If not please set out why you disagree. Please include any alternative costs and benefits you consider to be relevant and any evidence to support your views.
Agree
It is clear that further work on costings and fee levels is needed. While the information provided seems realistic, we are concerned about where in the system the funds would be found to support the costs of introducing and administering statutory regulation and the charging of registration fees, as well as the potential cost to individuals. We assume that if statutory regulation is introduced, it would be funded from an additional rather than an existing funding stream.
Do you think any changes to the level of professional assurance for the four medical associate professions could impact (positively or negatively) on any of the protected characteristics covered by the Public Sector Equality Duty, or by Section 75 of the Northern Ireland Act 1998.
No
We are not aware of any significant reasons why the changes being considered would impact on the Public Sector Equality Duty or S76 of the Northern Ireland Act 1998. However, our answer depends on Medical Associates and those working in healthcare who wish to become a medical associate, being properly supported and able to access the necessary levels of Continuing Professional Development (CPD) and training.