Can podiatrists bill for testing HbA1c? This is a nuanced question that touches on professional regulation, NHS commissioning, and clinical governance in the UK. HbA1c (glycated haemoglobin) is a key diagnostic and monitoring tool for diabetes, and its relevance to podiatric practice is well established — poorly controlled diabetes significantly increases the risk of diabetic foot complications. However, whether a podiatrist can independently request, perform, or seek reimbursement for HbA1c testing depends on their clinical setting, employer policies, and local pathology service agreements rather than HCPC registration alone.

What Is HbA1c Testing and Why It Matters in Podiatry

HbA1c reflects average blood glucose over two to three months and is the primary diagnostic tool for type 2 diabetes under NICE NG28; elevated levels directly inform podiatric risk stratification for complications such as foot ulceration and neuropathy.

HbA1c (glycated haemoglobin) is a blood test that reflects average blood glucose levels over the preceding two to three months. Under NICE guideline NG28 (Type 2 Diabetes in Adults), it is the primary diagnostic and monitoring tool for type 2 diabetes in the UK. A laboratory HbA1c result of 48 mmol/mol or above on two separate occasions (or once if symptomatic) is diagnostic of type 2 diabetes; a result of 42–47 mmol/mol indicates non-diabetic hyperglycaemia (sometimes referred to as prediabetes).

It is important to note that HbA1c is not appropriate for diagnosis in all circumstances. NICE NG28 advises that HbA1c should not be used as the sole diagnostic test in the following situations, among others:

• Pregnancy (including gestational diabetes)

• Suspected type 1 diabetes

• Haemoglobinopathies (e.g., sickle cell disease, thalassaemia) or conditions affecting red cell turnover (e.g., haemolytic anaemia, recent blood transfusion)

• Symptomatic hyperglycaemia where plasma glucose testing is more appropriate

In these situations, alternative diagnostic approaches should be used and the patient referred to their GP or appropriate specialist.

For podiatrists, HbA1c results carry significant clinical relevance. Poorly controlled diabetes is one of the leading causes of lower limb complications, including peripheral neuropathy, peripheral arterial disease, and delayed wound healing. Patients with elevated HbA1c levels are at substantially greater risk of developing diabetic foot ulcers, Charcot neuroarthropathy, and ultimately limb amputation. Understanding a patient's glycaemic control therefore directly informs podiatric risk stratification and treatment planning.

In practice, podiatrists working in both NHS and private settings frequently encounter patients with known or suspected diabetes. Awareness of HbA1c values helps clinicians:

• Assess wound healing potential in patients with active foot ulceration

• Stratify diabetic foot risk in line with NICE guideline NG19 (Diabetic Foot Problems: Prevention and Management)

• Identify possible undiagnosed diabetes in patients presenting with neuropathic or other relevant symptoms — noting that peripheral neuropathy has multiple causes and HbA1c testing is one component of a broader assessment

• Communicate effectively with GPs and multidisciplinary diabetic foot teams

Whilst HbA1c testing is clearly relevant to podiatric practice, whether a podiatrist can independently order or seek reimbursement for this test is a separate and more nuanced question, governed by professional regulation, NHS commissioning arrangements, and the specific clinical setting in which they work.

Podiatrists' Scope of Practice for Diagnostic Testing in the UK

Podiatrists' authority to request HbA1c is not determined by HCPC registration level but by local employer governance, pathology service acceptance criteria, and individual competency frameworks.

Podiatrists in the UK are regulated by the Health and Care Professions Council (HCPC) and, depending on their level of training, may hold a range of clinical competencies. The profession spans from standard podiatrists through to advanced practice podiatrists and podiatric surgeons, each with differing scopes of practice.

The HCPC's Standards of Proficiency for Chiropodists and Podiatrists do not explicitly grant or restrict the right to request specific laboratory investigations. Rather, the HCPC requires all registrants to practise within their competence and within the governance structures of their employing or contracting organisation. The authority to request diagnostic tests such as HbA1c is therefore not determined by HCPC registration level per se, but by local employer policies, pathology service acceptance criteria, and clinical governance frameworks.

In practice, whether a podiatrist — at any level — can request an HbA1c test depends on:

• The employing organisation's governance framework and clinical privileges

• Whether the local pathology service accepts requests from podiatrists (this varies between NHS trusts and integrated care boards)

• The podiatrist's individual competency and training record

• Local NHS trust or integrated care board (ICB) policies and clinical protocols

Advanced practice podiatrists working within NHS trusts or specialist multidisciplinary diabetic foot clinics may operate under locally agreed clinical protocols that permit them to request certain investigations, including HbA1c, as part of a structured care pathway. This is not a universal entitlement and must be explicitly agreed with the employer and the relevant pathology service.

It is important to clarify a common misconception: Patient Group Directions (PGDs) apply to the supply and administration of medicines only and do not confer authority to order diagnostic tests. Similarly, supplementary or independent prescribing qualifications relate to medicines, not to requesting laboratory investigations. Test-requesting rights are a separate matter governed entirely by local governance and pathology access policies.

In private practice, a podiatrist may wish to refer a patient to a private laboratory for HbA1c testing. However, many private laboratories restrict test requests to medical practitioners or other specifically approved clinicians; acceptance of requests from podiatrists varies and should be confirmed with the laboratory in advance. Scope of practice and funding or reimbursement rights are distinct considerations, and conflating the two can lead to governance and compliance issues.

Podiatrists seeking to expand their practice to include HbA1c ordering should engage with their employer, their ICB, the local pathology service, and the Royal College of Podiatry (RCPod) to ensure any such activity is properly governed, documented, and indemnified.

NHS and Private Funding Arrangements for HbA1c in Podiatry Settings

NHS podiatrists do not independently bill for HbA1c; costs are absorbed within service contracts, while private podiatrists may charge patients directly for point-of-care monitoring but cannot claim NHS reimbursement without an explicit NHS contract.

Within the NHS, funding for diagnostic tests such as HbA1c is governed by NHS England commissioning frameworks, integrated care board (ICB) contracts, and the NHS Payment Scheme (which replaced the former National Tariff Payment System). In general, podiatrists employed directly by the NHS do not independently seek separate reimbursement for HbA1c tests. Instead, tests are requested through established pathways — typically via a GP, hospital clinician, or a multidisciplinary team — and the cost is absorbed within the relevant care pathway or service contract.

For podiatrists working in NHS community services or specialist foot clinics, any HbA1c testing that occurs is usually funded through the overarching service level agreement (SLA) or block contract held by the provider organisation. The podiatrist themselves does not raise a separate charge; rather, the test is facilitated through the organisation's existing laboratory or phlebotomy arrangements.

In private podiatry practice, the situation is more flexible but also less regulated in terms of funding. A private podiatrist may:

• Signpost patients to their GP for an NHS HbA1c test

• Refer patients to a private laboratory, where the patient pays directly — noting that acceptance of requests from podiatrists varies between laboratories and should be confirmed in advance

• Include point-of-care HbA1c testing as part of a private consultation fee, using a validated near-patient testing device

It is important to note that private podiatrists cannot seek NHS reimbursement for HbA1c tests unless they hold a specific NHS contract that explicitly includes this activity. Attempting to claim NHS funding without such a contract would constitute an improper billing practice.

Regarding point-of-care testing (POCT) devices: podiatrists using near-patient HbA1c analysers in private practice should ensure the device is UKCA- or CE-marked for in vitro diagnostic use. The term 'MHRA-approved' is not applicable to devices; the MHRA does not approve individual devices but does publish guidance on the management and use of IVD point-of-care test devices, which sets out governance requirements including:

• Staff training and competency assessment

• Internal quality control (IQC) procedures

• External quality assurance (EQA) participation

• Device maintenance and calibration records

• Incident reporting procedures

Critically, POCT HbA1c should not be used to make a formal diagnosis of type 2 diabetes. Under NICE NG28, diagnosis requires a laboratory-based HbA1c measurement using a method traceable to the IFCC reference standard. POCT HbA1c may be used for monitoring glycaemic control in patients with a confirmed diagnosis, provided robust quality assurance processes are in place. Results from any POCT device should be documented and communicated promptly to the patient's GP.

HCPC and NICE Guidance on Roles and Responsibilities in Diabetic Foot Care

HCPC standards require podiatrists to practise within their competence and local governance structures; NICE NG19 and NG28 emphasise multidisciplinary HbA1c monitoring but do not determine which professions may request the test.

The HCPC's Standards of Proficiency for Chiropodists and Podiatrists outline the professional and clinical standards expected of registrants, but they do not explicitly grant or restrict the right to order specific laboratory investigations. The HCPC places responsibility on individual registrants to practise within their competence and to work within the governance structures of their employing or contracting organisation. Test-requesting rights are a matter of local clinical governance and pathology service policy, not HCPC registration category.

NICE guidance is similarly instructive on clinical roles. NICE guideline NG19 (Diabetic Foot Problems: Prevention and Management) and NICE guideline NG28 (Type 2 Diabetes in Adults) both emphasise the importance of HbA1c monitoring in patients with diabetes, and recommend that diabetic foot care is delivered by a multidisciplinary foot care team (MDFT). Within such teams, roles and responsibilities — including who requests investigations — should be clearly defined through local protocols agreed by the team and the organisation.

It should be noted that NICE guidelines do not determine which professional groups may request diagnostic tests; this is a matter of local governance. NICE NG19 and NG28 describe the clinical context in which HbA1c monitoring is important, but the authority to request such tests within a multidisciplinary team is established locally.

For podiatrists working within or alongside MDFTs, the following governance mechanisms may support extended roles, including test requesting, where locally agreed:

• Locally agreed clinical protocols endorsed by a responsible clinician or governance body

• Clinical privileges granted by the employing organisation following competency assessment

• Advanced or extended scope practice frameworks as described in RCPod guidance

Note that Patient Group Directions (PGDs) apply to medicines only (supply and administration) and do not authorise requesting diagnostic tests. Supplementary and independent prescribing qualifications similarly relate to medicines, not investigations.

The Royal College of Podiatry (RCPod) supports the development of advanced practice roles and has published guidance on extended scope practice, which may include diagnostic testing in appropriate settings. Podiatrists seeking to expand their practice to include HbA1c ordering should engage with their employer, their ICB, the local pathology service, and the RCPod to ensure any such activity is properly governed, documented, and indemnified. Acting outside agreed protocols — even with good clinical intent — may expose the practitioner to professional and legal risk.

How to Access HbA1c Testing Through the Correct Pathway

The most appropriate route for HbA1c testing is referral to the patient's GP, who can request a laboratory-based test through NHS pathology services; podiatrists should document clinical findings and communicate clearly with the GP rather than delaying urgent referrals.

For most patients seen by a podiatrist in either NHS or private settings, the most appropriate and straightforward route to HbA1c testing remains a referral to or communication with the patient's GP. GPs can request HbA1c as a routine blood test through NHS pathology services at no direct cost to the patient, and results are returned to the GP record where they can inform ongoing diabetes management. Importantly, a laboratory-based HbA1c result is required for formal diagnosis of type 2 diabetes under NICE NG28; point-of-care results alone are not sufficient for this purpose.

If a podiatrist identifies clinical indicators that suggest undiagnosed diabetes or poor glycaemic control — such as recurrent infections, slow-healing wounds, peripheral neuropathy (noting this has multiple causes), or unexplained skin changes — the recommended course of action is to:

• Document clinical findings clearly in the patient's notes

• Write to or contact the patient's GP with a clear clinical summary and request for appropriate testing, including laboratory HbA1c where indicated

• Advise the patient to make an urgent or routine GP appointment depending on clinical urgency

For active foot problems, podiatrists must be familiar with the urgent referral criteria set out in NICE NG19. The following situations require prompt escalation:

• Same-day referral to the multidisciplinary foot care service (MDFS): suspected acute Charcot neuroarthropathy; new or worsening foot ulceration in a person with diabetes; signs of infection or ischaemia in a diabetic foot

• Emergency referral or 999/A&E: limb-threatening or life-threatening diabetic foot problems, including severe infection, critical ischaemia, or systemic sepsis

Podiatrists should not delay urgent referral in order to await HbA1c results; glycaemic data can be obtained in parallel through the GP or hospital team.

In NHS multidisciplinary diabetic foot clinics, HbA1c testing is typically embedded within the patient's care plan and reviewed at each attendance. Podiatrists working within these teams should familiarise themselves with local protocols for accessing and acting on HbA1c results.

For private podiatrists wishing to offer point-of-care HbA1c testing as part of a comprehensive diabetic foot assessment, this is clinically reasonable for monitoring purposes provided:

• The device is UKCA- or CE-marked for in vitro diagnostic use

• The practitioner is trained in its use and interpretation, with competency documented

• Robust IQC and EQA processes are in place, along with maintenance records and incident reporting procedures, in line with MHRA guidance on IVD point-of-care test devices

• Results are clearly documented and communicated to the patient's GP in a timely manner, with an explicit note that laboratory confirmation is required if a new diagnosis of diabetes is being considered

Patients should always be encouraged to share results with their primary care team to ensure continuity of care and appropriate follow-up. This collaborative approach reflects best practice and aligns with the NHS Long Term Plan's emphasis on integrated, multidisciplinary management of diabetes and its complications.

Frequently Asked Questions