The information in this document is based on the Ministry of Health document, New Professions under the Health Practitioners Competence Assurance Act 2003 – Criteria for assessing applications for inclusion in the Act (2008).

“The principal purpose of the HPCA is to protect the health and safety of members of the public by providing for mechanisms to ensure that health practitioners are competent and fit to practice their professions” (p. 1)

For the minister to recommend that a health profession be regulated, (s)he must be satisfied that either

  • Lack of regulation poses a health risk to the public
  • It is in the best interest of the public that the health service be regulated

Given that most of the research evidence considering the risks of massage practice has generally found massage to be a very safe therapy, an application on behalf of the massage industry would be best served if it focuses on the benefits to the public of regulation.  A proposal which is focussed in this area must show that regulation would contribute to the health and safety of the public (p. 3)*. Presumably the application would focus on quality of service provision, improved client outcomes, evidence-based practice, etc.  The application should also provide examples of regulation overseas.

(* This is my interpretation of the document, but I am in the process of clarifying this point because it’s not completely clear to me)

“The minister must also be satisfied that the providers of health services are generally agreed on the

  • Qualifications for any class of providers of those health services
  • Standards that any class of service providers are expected to meet
  • The competencies for scopes of practice for those health services” (p. 2)

The developmental work which has been driven in New Zealand over the last 10 years by the professional associations and massage education providers has brought us to the point where we have a fairly clear idea of these issues.  There is some further development to be done before we reach the level needed for submission to a governmental organisation, but as an industry we are not far from that point.

It seems likely that the ministry would agree to appoint MNZ as the authority (assuming it doesn’t implode this weekend) as it is the sole representative of the massage industry.

The costs of setting up and operating the authority would need to be funded by the membership of the association.  In 2005 an independent firm valued the cost of setting up the authority as $20,000 – $40,000.  In addition to this, the annual cost of registration would need to be increased to about $1,000 pa based on the current level of membership (P. Gomas, personal communication, September 12, 2008).

While many see $1,000 as a prohibitive cost, I disagree.  Compulsory registration would stop some therapists practicing as “massage therapists”, leading to increased business for those who were adequately qualified.  I believe that this would more than compensate those who were carrying the burden.  Compulsory registration would also act as a pretty effective carrot to encourage MTs who are up to standard to join the association, and over the course of 2 years or so the costs should drop considerably.

If the costs of setting up the authority was funded by a loan, then the additional debt-servicing cost would not be too extreme.  If we assume that $40,000 was needed, that the period of repayment was over 30 years, and that the average interest rate over this time was 10% (fairly conservative estimations), then the monthly repayment cost would be $4,212 per annum.  Spread over the current membership this would equate to approximately $20 extra per annum, however as the level of membership rose this cost would reduce considerably, and the period of repayment could also be reduced.

Therapists who would be pushed out of the industry could still practice as “soft-tissue therapists”, or some other name, so there would be a need for a public education programme.  It might be possible to access some funding from health promotion sources for this?


New Professions under the Health Practitioners Competence Assurance Act 2003 – Criteria for assessing applications for inclusion in the Act (2008).  Retrieved September 11, 2008 from