In our view, the most persuasive criticism of recent reforms is not that they have been proven to harm patients. It is that governments have made them permanent, or scaled them up, before publishing an independent evaluation.
The record
- NSW made pharmacist UTI prescribing permanent on 1 June 2024, before its evaluation was released. Evidence: NSW Health announcement.
- Queensland made its pharmacy scope pilot business-as-usual from 1 July 2025 (Queensland Government). AMA Queensland called this “disappointing and dangerous” because it had not been independently evaluated (AMA Queensland, archived). Evidence: the Queensland Government statement; the AMA’s characterisation is an assertion. Tracker
- The UK’s 2023 NHS Long Term Workforce Plan set out to grow physician associates to 10,000 by 2036/37. Earlier independent studies existed, but none examined safety incidents: a 2025 BMJ review found that of 29 studies, none examined safety incidents and only one directly observed competence. Evidence: peer-reviewed review. Tracker
Why this argument works
It does not require proving harm, which is hard and slow. It holds reformers to the standard right-touch regulation sets for itself: quantify the risks, check for unintended consequences, and review. We think a pilot that becomes permanent before its evaluation is published takes the decision before those checks are complete.
It also survives the charge of self-interest. Pointing to doctors’ own interests may be a fair answer to claims that harm is inevitable. It is not an answer to “please publish the evaluation before you scale this up”.
What proponents say
Governments point to the absence of safety signals during trials, and to patients who cannot wait for, or afford, a GP visit. Those are reasonable points. But a trial with “no safety concerns”, as Queensland’s Health Minister put it, is not the same as a published, independent evaluation.
What we are asking for
For every scope expansion: a published evaluation plan, an independent evaluator, and a date. That is a modest ask, and it is consistent with right-touch regulation itself.