Physician associates and anaesthesia associates
GMC fitness to practise for physician associates and anaesthesia associates
The GMC has regulated physician associates and anaesthesia associates since 13 December 2024. It does so under the Anaesthesia Associates and Physician Associates Order 2024 rather than the Medical Act 1983. The grounds, the powers of case examiners and the appeal routes differ from a doctor's case. This page sets them out from the Order and the GMC's own pages, and covers what to do on day one and how we act for you on fixed fees.
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Day one
When the GMC letter arrives
Do
- Note every date. A notice proposing a Final Measure carries a deadline for your reasoned response. Silence can lead to a sanction without a hearing.
- Tell your indemnity provider or defence organisation at once. State indemnity in general practice covers clinical negligence claims, not regulatory matters.
- Keep the records, rotas and supervision notes connected with the concern, without altering anything.
- Write a private note of what you remember while it is fresh.
- Speak to us before you reply to the GMC, agree a Final Measure or sign anything.
Do not
- Reply to the GMC straight away to explain yourself.
- Contact the patient, the family or the person who raised the concern.
- Change or add to clinical records after the event.
- Discuss the case with colleagues or your supervising doctor as if the conversation were private.
- Post about it online, even in a closed group.
The stages
How an associate's case runs under the 2024 Order
Two grounds of impairment
Article 2 of the Order defines impairment for associates by two matters only. These are inability to provide care to a sufficient standard, and misconduct. The Medical Act 1983 sets six grounds for doctors in section 35C, including health, convictions and knowledge of English. The Order does not list those separately. How the GMC frames a concern under those two headings matters from the first letter. Our article on physician associates regulated by the GMC explains the differences.
Initial assessment and the case examiner
After initial assessment, article 10 lets the GMC refer a concern to a case examiner. The case examiner can find no impairment and close the case or issue a warning. Alternatively, the case examiner can find impairment and refer the case to a panel. The other option is what the Order calls a Final Measure: conditions, suspension or removal from the register.
A case examiner may impose a Final Measure in only two situations. The first is where you agree to it, accepting impairment and the findings. The second arises when the GMC gives you notice of a proposed Final Measure and asks for a reasoned response. If none arrives within the prescribed period, the case examiner may act. Treat that deadline as fixed. Send a reasoned response in time, even if you need to ask for more time to add to it.
Interim measures
While a case is open a panel can impose an interim measure of conditions or suspension. Under article 12 the GMC must review the measure before six months have passed from when it took effect. After that it must review it within six months of each previous review. It may not keep you under interim measures for the same matter for longer than 18 months. Only a court can extend that period. On review, the test is whether the measure remains necessary for the protection of the public. It may also continue if it remains in the public interest or your interests.
Panels
Where a case examiner refers the case, a panel decides it. We prepare the evidence and present your case, and a specialist barrister works with us from the outset.
Appeals
Under article 16 you can appeal to a panel against a case examiner's decision to impose a Final Measure. You must first seek permission from the GMC within 28 days of notice of the decision. Appeals against panel decisions go to the court under article 17. Diarise the 28 days on the day the decision arrives.
Titles and registration from 13 December 2026
The GMC's end of transition page sets out what changes on that date. Using the titles physician associate or anaesthesia associate without GMC registration will become a criminal offence under article 19 of the Order. Anyone not registered by then must stop working in the role until the GMC grants registration. If you have not applied, apply now and keep evidence of the date you did.
How we help
What you can expect from Eloquia
Saqib Khan leads your case from the first letter. A specialist barrister works alongside him from the outset, rather than appearing only once the GMC lists a hearing. We put the most effort in early, because the stage you can still influence is the one that repays preparation. We pair a clear account of the events, set against the records, with evidence of what you have done since. That gives the decision maker a reason to close the case or to choose the least restrictive outcome.
Before each stage starts, we confirm in writing what it covers and what it costs. You then decide whether to go ahead. You deal with the same people throughout. Where a hearing follows, we prepare the evidence, the witness statements and any expert report. We also prepare you to give evidence, and we present your case.
You may also face a police investigation, an inquest or a disciplinary process at work. If so, we run every track as one strategy, so that nothing said in one forum harms you in another.
Fees
The same fixed fee approach as for doctors
We quote a fixed fee for each stage before it starts, in the same way as we do for doctors. Every fee we quote is plus VAT. You pay stage by stage, so you never pay in advance for a hearing that may not happen. We do not act on conditional fee agreements. Our fee menu for GMC cases shows how we price the stages of a doctor's case. We price the stages of your case on the same basis. Has your indemnity provider, union or defence organisation declined to help? Read our page on cover refused or limited.
Each fee is plus VAT and includes a specialist barrister. We involve the barrister from the outset to give you additional support and advice. Fees do not include additional expenses such as expert fees, which we quote separately.
Read at source
The rules and guidance this page draws on
Sources
- The Anaesthesia Associates and Physician Associates Order 2024 (SI 2024/374)
- GMC: GMC regulation of physician associates and anaesthesia associates to begin (12 December 2024)
- The Anaesthesia Associates and Physician Associates Order 2024, article 10 (case examiners)
- GMC: End of transition for physician associates and anaesthesia associates (14 August 2026)
- The Anaesthesia Associates and Physician Associates Order 2024, article 12 (review of interim measures)
- Medical Act 1983, section 35C
- The Anaesthesia Associates and Physician Associates Order 2024, article 19 (offences)
- NHS Resolution: Clinical Negligence Scheme for General Practice
Questions and answers
Questions associates ask
Does the GMC use the same rules for physician associates as for doctors?
No. Associates are regulated under the Anaesthesia Associates and Physician Associates Order 2024, not the Medical Act 1983. The Order defines impairment by two matters only: inability to provide care to a sufficient standard, and misconduct. It also lets a case examiner impose a Final Measure in some circumstances. Our article on physician associates regulated by the GMC explains the differences.
Can a GMC case examiner suspend a physician associate without a hearing?
Only in two situations under article 10 of the Order. The first is where you agree to the Final Measure, accepting impairment and the findings. The second arises when the GMC gives you notice of a proposed Final Measure and asks for a reasoned response. If none arrives within the prescribed period, the case examiner may impose the measure. A reasoned response sent in time keeps the decision with a panel.
How long can an interim measure on an associate last?
The GMC may not keep you under interim measures for the same matter for longer than 18 months. Only a court can extend that period. It must review the measure before six months have passed and then within six months of each previous review. On each review it asks whether the measure remains necessary for the protection of the public. The measure may also continue in the public interest or your interests.
How do I appeal a case examiner's Final Measure?
Under article 16 you can appeal to a panel. You must first seek the GMC's permission within 28 days of notice of the decision. Appeals against panel decisions go to the court under article 17. Diarise the 28 days on the day the decision arrives.
What changes on 13 December 2026?
The GMC states that the law changes on that date. Using the titles physician associate or anaesthesia associate without GMC registration will become a criminal offence. Anyone not registered must stop working in the role until the GMC grants registration. If you have not applied, apply now and keep evidence of the date.
Does Eloquia act for associates on fixed fees?
Yes. We quote a fixed fee for each stage before it starts, and every fee is plus VAT. Each fee includes a specialist barrister from the outset. We quote expert fees separately. Our fees and funding page explains how staged payment works.
More answers sit on our questions and answers page, and our glossary explains the terms regulators use.
Read more
Guides on this subject
Other professions
Physician associates regulated by the GMC: what regulation since December 2024 means
Physician associates have faced GMC fitness to practise since 13 December 2024 under their own Order. Here is how it differs.
Cover and fees
Does your indemnity cover a GMC investigation?
Your indemnity for patient claims and the money to defend a GMC investigation are two different things. Many doctors find the gap late.
The GMC process
Interim orders tribunals: what they decide, how often they suspend and how to prepare
The section 41A test an interim orders tribunal applies, what it decides, the 2025 figures and how to prepare.
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