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Seeking your views on the possible regulation of physician associates under the HPCAA 2003


Tēnā koutou
 
Manatū Hauora | Ministry of Health (the Ministry) has recently launched a targeted consultation on a proposal to regulate the physician associate profession (PAs) under the Health Practitioners Competence Assurance Act (HPCAA).
 
The Ministry’s proposal relates to the possible regulation of the profession, and therefore focusses primarily on the risk of harm involved in the practice of the profession and what regulatory mechanisms should be employed to minimise those risks.
 
Te Kaunihera Rata o Aotearoa | Medical Council of New Zealand (Council) is one of 65 stakeholder organisations invited to respond. The Ministry advises that the Council has been invited to make a submission as medical practitioners work alongside and supervise PAs.
 
The criteria for the Ministry on whether to regulate a profession include an assessment of the existing regulatory mechanisms and the practicality of regulating the profession under the HPCAA.  The Ministry has also invited feedback on whether the benefits of regulation outweigh the negative impacts of regulation. 
 
According to the Ministry, there are 33 PAs currently practising in New Zealand under supervision, with a further 17 proposed to be employed in the short term. 
 
The regulation of physician associates under the HPCAA presents a multifaceted issue that will have an impact on all doctors (and other professions) given the supervisory requirements PAs may be working under, and the potential costs of regulating a relatively small number of practitioners.
 
The Council, therefore, sees it as crucial that the medical profession is able to inform, contribute and participate in the current proposal.  Consequently, the Council is engaging with doctors and other stakeholders, with the Ministry’s proposal and key questions we are seeking your views on. Your insights and perspectives will be critical in shaping our response to the Ministry.
 
We are providing you with an abridged version of the Ministry’s consultation document.  This version excludes some administrative information and the specific questions that the Ministry has asked the Council to respond to. 
 
We note that the question of which regulatory authority might govern the PAs if regulated under the HPCAA is not addressed in the Ministry’s consultation document. The Council has concerns regarding the possibility of there being one authority regulating both medicine and physician associates. We are interested in your view.
 
We invite you to respond to our questions by Thursday, 27 July 2023.

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* 1. Please tell us who you are.

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* 2. Does the current practice of PAs pose a risk to public health and safety?

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* 3. Are the existing controls on the practice of PAs sufficient to ensure public health and safety? If not, what additional steps could be taken?

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* 4. PAs practice under the supervision of medical practitioners. What impact, if any, would the recognition of PAs as a profession under the HPCAA have on the responsibilities of doctors?

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* 5. PAs will, for the foreseeable future, be trained overseas. What would be required to ensure PAs are equipped to provide culturally-safe health care and support equitable health outcomes in Aotearoa New Zealand?

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* 6. PAs will, for the foreseeable future, be trained overseas. What implications, if any, would that have on the current health workforce for orientation/induction and supervision needs?

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* 7. Should PAs be regulated under the HPCAA? If so, why?  If not, why not?

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* 8. Do you think that doctors and PAs (if regulated under the HPCAA) should be jointly regulated under an existing regulatory authority (for example the Medical Council, or an alternative regulatory authority)?

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* 9. Please provide any other comments you may have about the regulation of physician associates that you would like us to consider.

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