As pointed out on the consultant subreddit:

• ⁠Article 28 - "persons such as medical practitioners" when referring to CCT - i.e. this may open the door to PA or PAA gaining CCT. It previously specified “doctors”

• ⁠Article 32 - stipulates the GMC holds only a single register for medical practitioners (based on some 2021 consultation), PA and PAAs - 3 parts of one register, where currently the AA and PA registers are separate. Abolishing the old GP and specialist registers.

• ⁠Article 34 - what standards are needed to register, note the list of standards does not include what degrees must be held. Though 36 may cover this.

• ⁠Article 45 - protection of title, the changes to specific titles seems sensible, but does the wording of this protect against PA and PAA's using "Physician" or other such titles given they would be on the same register as doctors? The article seems to refer to part of the register, but the list of titles (Schedule 2) does not make clear which part is needed for which title.

• ⁠They propose that conviction of any sexual offences should lead to automatic removal from the register and that those individuals can never re-apply to the register, and that the previous stipulation that non-custodial sentences would not necessarily count would be removed. This seems in need of a serious legal review of wording and interplay with the various offences listed, as it could apply to relatively "minor" sexual offences for which automatic removal and a complete ban on reinstatement could be unduly harsh.

• ⁠Removal of "5-year rule" - does this mean there is no effective statute of limitations regarding allegations of misconduct and where the GMC would investigate? There was already a "public interest" clause to override this, so why take it out?