British Medical Association (BMA) (2026) Preventing doctor substitution. Available at: https://www.bma.org.uk/advice-and-support/nhs-delivery-and-workforce/workforce/preventing-doctor-substitution

The characterisation of advanced practitioners as a form of “doctor substitution” is not supported by UK policy, regulation, or professional consensus. Advanced practice is clearly defined as a level of practice within existing regulated professions, achieved through additional education, training, and experience, and delivered within clear governance and professional boundaries. It is designed to support, not replace, multidisciplinary care (NHS Employers, 2026).

AAPE UK reaffirms that advanced practice represents a recognised progression of professional practice, with practitioners regulated through their underpinning professional registration that enhances care delivery across teams. Assertions that it inherently compromises patient safety are not supported by current regulatory evidence. Independent review by the Health and Care Professions Council (HCPC) found no evidence that advanced practice within regulated professions presents a unique or inherent risk to the public when practised within appropriate governance structures (HCPC, 2024).

Advanced practitioners are already subject to rigorous professional regulation and must practise within defined scopes, supported by continuing professional development and organisational governance structures. Advanced practitioners are regulated through their underpinning professional registration and governed by national frameworks defining advanced practice across the four UK nations. National frameworks provide consistent standards for advanced practice, built on the well-established pillars of clinical practice, leadership, education, and research (NHS England, 2025; Chief Allied Health Professions Officers, 2024).

In addition, the Nursing and Midwifery Council (NMC) is progressing work to strengthen consistency and public assurance through its Advanced Practice review and the development of Principles for Advanced Practice. These principles reinforce expectations for safe, effective, and well-governed practice, clarify the level of practice required, and align with UK-wide frameworks to support high standards of care and public confidence (NMC, 2024; NMC, 2025).

This ensures that advanced practice is one of the most structured and carefully governed workforce developments within the NHS.

Importantly, advanced practice must be viewed within the context of increasing healthcare demand, growing patient complexity, and the need for timely, accessible care. Advanced practitioners play a critical role in improving timely access to care, reducing delays, and supporting continuity for patients with complex and long-term conditions, while enhancing multidisciplinary team capacity and patient-centred service delivery (NHS England, 2025; NHS Employers, 2026).

AAPE UK is concerned that the language of “substitution” risks undermining the trust and collaboration essential to effective multidisciplinary working. Patient safety is best achieved through integration of expertise across professions, not through narratives that create division. Nurses, allied health professionals, and other advanced practitioners are expert contributors to clinical care, leadership, and service transformation, working alongside medical colleagues to improve patient outcomes.

We fully support the need for clarity in professional roles and transparent communication with patients. These requirements are already embedded within regulatory frameworks and are further strengthened through the evolving work of regulators, including the NMC’s development of advanced practice principles to improve consistency, governance, and public understanding (NMC, 2024). The appropriate response to concerns is therefore continued strengthening of governance, consistency, and education and not restriction of advanced practice.

AAPE UK recognises the vital role of doctors within the NHS and shares the BMA’s commitment to patient safety and professional integrity. However, we firmly assert that advanced practice is not doctor substitution. It is a regulated, evidence-based and essential component of modern multidisciplinary healthcare that strengthens, rather than diminishes, the quality and safety of care.

The future of healthcare depends on integrating expertise across professional groups, supported by strong governance, shared standards, and mutual respect. We therefore call for continued collaborative dialogue, alignment with national policy and regulatory evidence, and a collective focus on delivering safe, effective and patient-centred care.

AAPE UK remains committed to working collaboratively with stakeholders to effectively articulate role distinction and to support informed, constructive discussions as this agenda progresses.

Reference List

Chief Allied Health Professions Officers (UK) (2024) Advanced practice in the Allied Health Professions (AHPs). Available at: https://www.hcpc-uk.org/globalassets/news-and-events/blog/four-country-ap-statement-oct-2024.pdf

Health and Care Professions Council (HCPC) (2021) Advanced Practice Final Independent Research Report Available at: https://www.hcpc-uk.org/resources/policy/advanced-practice-full-research-report/ 

Health and Care Professions Council (HCPC) (2024) Updates on advanced practice. Available at: https://www.hcpc-uk.org/news-and-events/blog/2024/updates-on-advanced-practice/ 

Health and Care Professions Council (HCPC) and General Osteopathic Council (GOsC) (2026) Shared update on the regulation of advanced levels of practice. Available at: https://www.hcpc-uk.org/standards/meeting-our-standards/advanced-levels-of-practice/regulating-advanced-levels-of-practice/

NHS Employers (2026) Position statement on advanced practice. Available at: https://www.nhsemployers.org/articles/position-statement-advanced-practice-1

NHS England (HEE) (2025) Multi-professional framework for advanced practice 2025. Available at: https://advanced-practice.hee.nhs.uk/multi-professional-framework-for-advanced-practice/

Nursing and Midwifery Council (NMC) (2024–2025) Advanced practice review. Available at: https://www.nmc.org.uk/standards/future-standards/advanced-practice-review/

Nursing and Midwifery Council (NMC) (2025) New principles for advanced practice to bring clarity and consistency. Available at: https://www.nmc.org.uk/news/news-and-updates/new-principles-for-advanced-practice-to-bring-clarity-and-consistency/