The College of Medical Associate Professionals (CMAPs) has requested clarification regarding IR(ME)R training and Non-Medical Referrer (NMR) entitlement for Physician Associates (PAs) and Anaesthesia Associates (AAs) from the Royal College of Radiologists (RCR) following their recent statement.
Since December 2024, the General Medical Council (GMC) has been formally established as the regulator for PAs and AAs. This milestone ensures clear professional oversight and governance for these roles. The most recent statement published by the RCR on 29th January 2025 regarding PAs and AAs requesting ionising radiation imaging investigations necessitates further clarification.
Under IR(ME)R, non-medical professionals are entitled to refer for imaging within a defined scope. The statement acknowledges this entitlement while highlighting the need for additional training. However, the assertion that “it would be premature for PAs and AAs to undertake this training, and so they should not request imaging examinations for patients, until such time as the [Leng] Review is completed and their scope of practice is agreed” presents concerns. This position undermines the role of PAs and AAs in clinical practice and their status as fully registered professionals.
Delaying training until the completion of the Leng Review restricts the development of necessary skills and limits safe professional advancement. IR(ME)R training enhances safe practice and should be encouraged.
The GMC has already confirmed that:
“PAs and AAs who are registered with the GMC may be eligible to become ‘non-medical referrers’ (NMRs) for ionising radiation, providing their employer has entitled them as an NMR and they have undergone the appropriate training. Decisions on which members of staff can be trained and act as NMRs are a matter for individual employers.”
This guidance reinforces that employer-led entitlement, based on training and competency, determines whether PAs and AAs can refer for imaging.
The Leng Review remains an important ongoing process, but it does not supersede existing regulatory frameworks or eliminate the authority of employers to grant entitlement in accordance with IR(ME)R.
Concerns Regarding the Current Position
The current statement is being used by NHS trusts to prevent PAs and AAs from undertaking IR(ME)R training and obtaining NMR entitlement without a legal or regulatory basis. This practice creates workforce inefficiencies and increases the burden on other clinicians. It perpetuates inconsistencies in governance, with some trusts adhering to GMC and IR(ME)R guidance while others defer to external statements. Restricting imaging referrals without justifiable grounds contributes to unnecessary service delays for patients.
Equating PAs and AAs to band 4 Nursing Associates is misleading and highly inappropriate. PAs and AAs are GMC-regulated professionals with the capability to make educated clinical decisions and they should therefore be assessed based on their competency as band 7 practitioners.
Clarification and Collaboration
As a key professional body influencing imaging governance, the RCR plays a crucial role in shaping safe practice. It remains essential to support appropriately trained professionals in working within their competencies without imposing unnecessary barriers to training.
A request has been made to work collaboratively to provide clarity for employers and to ensure that their current position does not override IR(ME)R and GMC guidance. NHS Trusts must be enabled to make entitlement decisions based on employer-led frameworks.
Statements should support, rather than hinder, PAs and AAs in accessing appropriate training and entitlement, acknowledging their GMC-regulated status and established clinical roles. A competency-based approach must guide these decisions, ensuring that training and capability take precedence over blanket restrictions.
A collaborative effort to align governance frameworks with national regulations remains essential. A fair, structured, and evidence-based approach to training and entitlement for PAs and AAs in imaging services is required.
