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HPCSA Updates Booklet 20 and Redefines AI Use in Allied Health

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The Health Professions Council of South Africa (HPCSA) has released the updated Booklet 20 – Ethical Guidelines on the Use of Artificial Intelligence, alongside other revised ethical guideline booklets. (HPCSA Link) For allied health practitioners in private practice, this ruling marks a pivotal moment. As AI models and decision-support tools become more integrated into care, the onus is on the practitioner to ensure ethical, clinically-sound, and patient-centred use of AI systems.

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Ethical use of AI in Healthcare.  
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What’s New in Booklet 20

While the HPCSA’s earlier guidance (and many global frameworks) discussed AI in general, the revised Booklet 20 explicitly sets out how AI must be used within the South African healthcare context. Key updates include:

  • A clear statement that AI must never supplant the practitioner’s professional judgment: your role remains central. (Bowmans Law)
  • Emphasis on transparency and explainability of AI tools: practitioners should understand how these systems generate output and cannot rely on “black-box” reasoning without scrutiny.
  • A focus on data bias, fairness and equity: AI systems trained on historical or skewed datasets may reproduce discriminatory patterns. Booklet 20 warns of this risk.
  • Clarification of liability and accountability: even when AI tools are used, the practitioner remains legally and ethically accountable for the decisions made and care provided.
  • Specific guidance for AI use in digital workflows, telehealth, decision-support and patient engagement: the booklet connects AI use to established HPCSA practices rather than treating AI as a standalone domain.
  • A requirement to inform patients when AI-tools are used in their care, and to preserve patient autonomy, confidentiality and informed consent in situations involving AI.

This update reaffirms that AI is a tool, never a substitute for the ethical, human-centred practise of allied health professionals.

Why This Matters for Allied Health Practitioners

For allied health disciplines, including physiotherapy, occupational therapy, podiatry, speech-language therapy and others, this guidance has very real implications:

  • Integration of AI-enhanced tools (for example gait-analysis software, tele-rehabilitation platforms, outcome-prediction algorithms) is increasing. Booklet 20 provides a framework to evaluate such tools and align them with your ethical obligations.
  • Billing and records workflows may embed AI-components in for example, scheduling/triage-algorithms, automated patient-report generation or outcome-tracking dashboards. You must ensure such components do not compromise professional judgment or patient confidentiality.
  • Patient trust and transparency are critical. If you employ AI-tools (even “behind the scenes”), Booklet 20 emphasises you must ensure patients know, and understand, how these tools are part of their care.
  • Risk management: as AI becomes more widely used, you may face new forms of liability. If an AI tool mis-classifies something and you rely uncritically on it, the HPCSA emphasises you remain accountable.
  • Training and governance: Allied health practices must now be proactive in adopting governance frameworks around AI use. It’s your responsibility to ensure staff are trained, systems are audited and ethical-protocols built in. Booklet 20 supports this proactive posture.
  • Competitive advantage: Practices that confidently adopt AI tools within an ethically-sound framework will be better positioned to deliver efficient, high-quality care, while avoiding the pitfalls of misuse, regulatory scrutiny or loss of patient confidence.

Five Practical Steps We Recommend You Take

  1. Identify where you’re currently using or could be using AI. What tools do you currently use (or plan to) use for diagnostic research, outcome-prediction, reporting, or data interpretation.
  2. You’ll need to build your AI-governance checklist aligned to Booklet 20 and does it anwer the following criteria:
    • Does the tool allow practitioner oversight?
    • Is it transparent?
    • Does it respect data-bias issues
    • Can it safeguard patient confidentiality?
    • Can I include informed consent where needed?
  3. Train your team. Ensure all staff understand that the AI tool is adjunctive, that they must question the outputs it generates, and that they remain accountable.
  4. Update your patient-communication protocols. If an AI-component is involved in their care, ensure you disclose it appropriately and document it in your patient/client files.
  5. Revise your records and audit workflows: Ensure AI-derived outputs or recommendations are clearly labelled as such.

From Innovation to Ethical Implementation

The HPCSA’s Booklet 20 update marks an important milestone for the industry, recognising that digital health innovation is rapidly shifting, but that the professional, human-centred core of allied health practice must remain intact. As South Africa’s healthcare system grapples with workforce shortages, cost-pressures and widening demand, AI offers significant opportunities. Equally significantly it presents ethical, professional and legal risks that must be evaluated and mitigated against. Like any tool in your practice, you need to plan for its use and proper implementation.

For allied health professionals and private practices, the message is clear: embrace innovation, but do so intentionally, ethically and in alignment with your professional obligations. Booklet 20 provides a roadmap to do just that.