Possible regulation of physician associates under the HPCAA


Manatū Hauora | Ministry of Health is the agency responsible for the proposal and consultation on the regulation of physician associates under the Health Practitioners Competence Assurance Act 2003. The Medical Council made a submission during the Ministry’s consultation on the proposal in December 2023 (as did a number of other organisations) and is awaiting the Ministry’s release of the outcome. The Medical Council cannot advise on when this information will be released by the Ministry.

In summary, the Council's submission notes that:

  • The Council’s view is that the risk of harm posed by the small number of physician associates (PAs) currently practising in New Zealand is not sufficient to require regulation under the Health Practitioners Competence Assurance Act 2003 (HPCAA). 
  • The Ministry's proposal does not include a substantive analysis of potential disadvantages and costs, relative to the potential benefits of regulation under the HPCAA that are canvassed in the document. This cost benefit analysis is needed to ensure that present risk is managed at a suitable level and in a fiscally responsible way.
  • There are several other ways to manage current risk without pursuing regulation. Analysis of these other options could demonstrate whether the costly and complex choice to regulate under the HPCAA is the most appropriate option.
  • Consistent standards of qualification and practice is an important aspect of regulating for public safety. PAs in the United States and Canada are not subject to regulation in every state and province, and as such there are inherently variable standards of qualification and practice.
  • Regulation under the HPCAA would first require creation of a New Zealand PA training programme and standard of practice, against which to assess the qualifications and competence of PAs trained overseas.
  • Regulation of PAs is likely to result in an increased presence of an overseas trained profession that requires induction, orientation and supervision, from a senior clinical workforce that is already under pressure.
  • Given the small number of PAs in New Zealand, regulation does not seem a proportionate pursuit at this time. It would be more efficient and cost-effective to first explore existing mechanisms, other than regulation under the HPCAA, that could more proportionately address any risk.
  • Should the context change, this proposal could be revisited in future, for example, if a New Zealand PA training programme is established, or if there is a significant increase in the number of PAs working in New Zealand, as these factors could impact of the level of risk.


  • Council's submission to Manatū Hauora | Ministry of Health on their consultation around the regulation of physician associates under the Health Practitioners Competence Assurance Act 2003.