AHCS Latest update on PGD's

26 March 2026 by AHCS

Sent on behalf of Professor Chris Hopkins, President, AHCS and Chair, Professional Bodies Council

Dear Colleagues,

I am writing to update the Professional Bodies Council on the outcome of a recent Freedom of Information (FOI) request I submitted to the MHRA, and on the subsequent clarification I have sought from Professor Suzanne Rastrick, the SRO for this work.

The FOI request was in relation to the discussions and decisions made by the Commission on Human Medicines (CHM) concerning Patient Group Directions (PGDs) for both Clinical Scientists and Biomedical Scientists. The information released confirms that CHM reached a consistent position across its 2021 and 2023 reviews:

Diagnostic PGDs: CHM expressed clear support for the use of diagnostic PGDs by both Biomedical Scientists and Clinical Scientists, subject to appropriate training, robust governance arrangements, and a clearly defined scope of practice.

Therapeutic PGDs: CHM did not support their introduction at this stage, identifying the need for more evidence, clearer and more specific use case examples, and an assessment of risk, benefit, and patient impact.

What is particularly notable, and concerning, is that despite CHM’s explicit support for diagnostic PGDs, there appears to have been no progress in taking this forward into legislative change under the Human Medicines Regulations. Given the potential benefits for diagnostics, service efficiency, workforce flexibility, and patient pathways, this lack of progression requires clarification.

To that end, I have written to Professor Suzanne Rastrick to seek further understanding of why the supported elements of the proposal were not advanced, and what the anticipated next steps may be. We have a meeting scheduled for 21st April, during which we will also discuss therapeutic PGDs in more detail.

In the meantime, I wanted to ensure that all professional bodies and the wider UK healthcare science community are aware of the current position and the content of the FOI response. I have attached the consolidated minutes from the CHM’s 2021 and 2023 deliberations for your reference.

I will provide a further update following the April meeting.

Best wishes,

Professor Chris Hopkins

President - Academy for Healthcare Science

View other News