Preventing doctor substitution

Our response to activity by government departments, NHS bodies, NHS employing organisations, and statutory education and training bodies, that diminish the role of doctors or impact their education and training through the inappropriate use and unsafe expansion of non-doctor roles.

Location: UK
Audience: All doctors
Updated: Wednesday 23 September 2026
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Addressing growing concerns

The BMA supports multidisciplinary team working and recognises the crucial roles that different staff perform in the NHS. However, concerns have been raised across the medical profession about unhelpful and inappropriate blurring of the distinction between doctors and non-medically qualified staff.

We have heard of patient safety concerns resulting from non-medical clinicians being supported by their employers to work outside of their competency, or without sufficient supervision, or in ways that negatively impact the education and training of medical students and doctors.

When considering the safety of physician assistants and physician assistants (anaesthesia), we have also heard concerns about other clinicians being used as substitutes for doctors; particularly those working at the ‘advanced practice’ level. Our work in this area has allowed us to better understand the experiences of doctors working with non-medical clinicians, and of patients receiving care. 

Doctor substitution reporting portal

In January 2026, we launched a new reporting portal through which doctors and medical students could report issues around any form of doctor substitution, many of which have related to advanced practitioners. When submitting concerns through our portal, the BMA was clear to submitters that incidents should additionally be reported through formal mechanisms. Our report collates all of the submissions relating to patient safety we have received relating to advanced practitioners.

You can read the full report below.

 

Please continue to use our reporting portal to share your experiences without identifying any other healthcare professional or patient:

Reporting portal

We may use submissions to inform and assist local engagement with employers by BMA staff and BMA local or regional representatives.  We may also use or summarise your submission in media work, the BMA's own publications and/or lobbying on behalf of our members. Your personal information will be anonymised.

You will not routinely receive a response to a submission made through this portal. If you have a concern that requires a response, please make sure to raise it with a BMA advisor.

Important

 

This form is not a substitute for the formal reporting mechanisms available to all doctors to raise patient safety concerns or to report missed educational or training opportunities. Further information on how to raise concerns can be found on our website.

Survey findings

A survey of doctors and medical students on the use of advanced practitioners in the NHS was conducted by the BMA during January and February 2026. 5299 valid responses were received, and you can read the full survey report.

The BMA has called for swift action from Government to protect patients as its survey of doctors reveals widespread fears for patient safety over the chaotic way employers use advanced practitioners. More than four fifths of doctors answered ‘sometimes’ or ‘frequently’ to the question do you believe the way that advanced practitioners currently work in the NHS is a risk to patient safety? Read further details on this.

Unsafe filling of rota gaps

BMA freedom of information requests of UK hospital Trusts and Boards have revealed that many are putting less-qualified staff on doctors’ rotas in place of a doctor. Almost half the employers who responded said “yes” when asked if they permitted Advanced Practitioners to cover doctors’ rota gaps (41 Yes to 44 No). When challenged, many offending trusts have responded by stating that substitution is both prohibited and facilitated. Responses from trusts are provided below.

Why this matters

The BMA’s view aligns with the World Medical Association’s Statement on Scope of Practice, Task Sharing and Task Shifting. If cohorts of non-medical clinicians are enabled and encouraged by their employers to perform tasks above their accepted level of competence (or within their competence but without supervision from a doctor where necessary), this risks decreasing the safety and quality of care.

It also risks delayed, incorrect or overdiagnosis, incorrect treatment and inability to deal with complications, fragmented and inefficient service and lack of proper follow up. It may also increase the overall cost of care, as non-doctor health personnel are more likely to rely on consultations, and diagnostic and other tests, to compensate for their lesser education and training compared to doctors. 

We have used the information gathered to challenge government departments, NHS bodies, NHS employing organisations, and statutory education and training bodies, who have sought to diminish the role of doctors, or impact their education and training, through inappropriate utilisation and unsafe expansion of non-doctor roles.

 

About advanced practice

Advanced practice is a level of progression open to a wide range of non-medical clinicians in the multi-disciplinary team. The following publications provide a range of regulatory, professional body, and NHS guidance on frameworks, principles, and definitions used across the NHS: